20181211Reply Comments.pdf

Y ROCKY MOUNTAIN
BP,yy,En".,
RECEIVED
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1407 W. North Temple, Suite 330
Salt Lake City, Utah 84116
December I l, 2018
VA OVERNIGHT DELIVERY
Idaho Public Utilities Commission
472West Washington
Boise, lD 83702-5983
Attn: Diane Hanian
Commission Secretary
RE: Case No. PAC-E-18-07
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,
Michael S. Snow
Manager, DSM Regulatory Affairs
Enclosures
-/,ZfS-r*{
Daniel E. Solander, (ISB# 8931)
Rocky Mountain Power
1407 West North Temple, Suite 320
Salt Lake City, Utah 841l6
Telephone: [phone]
Email: [e-mail]
Attorneyfor Roclqt Mountain Power
BEFORE THE 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.18.O7
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.
BACKGROUND
L On August 24, 2018, the Idaho Public Utilities Commission ("Commission")
issued aNotice of Modified Procedure in OrderNo.34175 forthe above referenced matter,
allowing parties to file comments by December 4,2018, with the Company's reply comments
due by December ll, 2018. Commission Staff ("Staff') and PacifiCorp Idaho Industrial
Customers ("PIIC") filed comments December 4,2018. The Company provides these reply
comments in response to comments filed by Staff to add some clarifications.
2. First, the Company notes that PIIC does not dispute the prudence of the
Company's 2016-2017 Demand Side Management ("DSM") expenditures, and Staff
recommends the Commission order that the Company prudently incurred 94,491,122 in20l6
and $4,038,931in 2017 DSM tariff rider expenses.
REPLY COMMENTS OF
ROCKY MOI.INTAIN POWER
Page I
REPLY COMMENTS
3. The title of Table I in Staff s comments was listed as the "Customer Efficiency
Services Tariff Rider Balance - Cash Basis." The Company would like to clarify that the values
listed in Table I account for the Accrual Basis rather than Cash Basis and should be listed as
such.
4. Table 2 in Staffs comments compares the Company's energy savings at site
against the Integrated Resource Plan ("IRJ"'I targets at generator. The Company has included
an updated Table 2 below with an additional row to show the achieved energy savings at
generator for clarity.
Table 2. Rocky Mountain Power's Idaho DSM Portfolio,2016 and2017 (UPDATED)
METRIC 2016 2OI7
SAVINGS (AT SITE)
SAVTNGS (AT GENERATOR)
IRP TARGET (AT GENERATOR)
EXPENDITURES
UTILITY COST TEST
TOTAL RESOURCE COST TEST
REPLY COMMENTS OF
ROCKY MOUNTAIN POWER
5. Staff recommended two possible solutions for ensuring that evaluation costs are
fully reflected in cost-effectiveness calculations, but do not inordinately impact cost-
effectiveness results from year-to-year. The Company will discuss these options with Staff, as
well as other options, to identify an agreeable solution going forward.
6. When commenting on the Company's Low Income Weatherization ("LIW")
Program, Staff noted that it was almost cost-effective in 2016 with a Total Resource Cost
("TRC") ratio of 0.96, and cost-effective in2017 with a TRC ratio of 1.41. The Company
19,450 MWh
21,551MWh
15,800 Mwh
$4,500,332
2.22
1.59
15,830 MWh
17,514 MWh
17,570 MWh
$4,038,931
2.19
t.7t
Page2
would like to clariff that the LIW Program's cost-effectiveness is determined by the PacifiCorp
TRC ("PTRC"), per the Commission's Order No. 32788. That being the case, the LIW
Program was cost-effective in 2016 and2017 with a PTRC of 1.04 and 1.45, respectively.
7. Staff also recommended the Company resume meeting with Staff at least semi-
annually to allow sufficient time to discuss DSM programs. The Company agrees with this
recommendation and will work with Staff to schedule meetings accordingly.
8. On December 7 and 10, 2018, the Company discussed Staff s comments with
Staff, and Staff supports the clarifications the Company has included in these reply comments.
REQUEST FOR RELIEF
WHEREFORE, Rocky Mountain Power respectfully requests that the Commission
find that the20l6-2017 DSM expenditures were prudently incurred as recommended by Staff.
DATED this I lth day of December,20l8.
Respectfully submitted,
By
Daniel E. Solander
Attorney for Rocky Mountain Power
4,fih
REPLY COMMENTS OF
ROCKY MOLINTAIN POWER
Page 3
CERTIFICATE OF SERVICE
I hereby certiff that on this l lth of December,20l8,I caused to be served, via E-mail a
true and correct copy of Rocky Mountain Power's Reply Comments in PAC-E-18-07 to the
following:
Service List
PACIFICORP IDAHO INDUSTRIAL CUSTOMERS (PIIC)
Ronald L. Williams
Williams Bradbury, P.C.
P.O. Box 388
Boise ID, 83701
ron@wi ll iamsbradbury.com
Jim Duke
Idahoan Foods
[e-mail]
Kyle Williams
BYU Idaho
[e-mail]
Val Steiner
Nu-West Industries, Inc.
val. steiner@agrium. com
MONSTANTO
Randall C. Budge
Racine Olson, PLLP
P.O. Box 1391
201E. Center
Pocatello, lD 83204-139 I
[e-mail]
Thomas J. Budge
Racine Olson, PLLP
P.O. Box 1391
2018. Center
Pocatello, ID 83204-1 391
[e-mail]
Brubaker & Associates
16690 Swingley Ridge Rd., #140
Chesterfield, MO 63017
mbrubakerfDconsultbai.com
IDAHO IRRIGATION PUMPERS ASSOCIATION, INC (IIPA)
Eric L. Olsen
ECHO HAWK & OLSEN, PLLC
505 PershingAve., Ste. 100
P.O. Box 6119
Pocatello, Idaho 83205
[e-mail]
Anthony Yankel
12700 Lake Avenue, Unit 2505
Lakewood, Ohio 44107
[e-mail]
COMMISSION STAFF
Edith Pacillo
Deputy Attorney General
Idaho Public Utilities Commission
472 W. Washington (837 02)
PO Box 83720
Boise, lD 83720-0074
[e-mail]
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PACIFICORP, DBA ROCKY MOUNTAIN POWER
Ted Weston
PacifiCorp, dba Rocky Mountain Power
1407 West North Temple
Suite 330
Salt Lake City, UT 84116
ted.weston@pacifi corp.com
Daniel Solander
PacifiCorp, dba Rocky Mountain Power
1407 West North Temple
Suite 330
Salt Lake Ciry, uT 84116
daniel. solander@nacifi corp.com
Michael Snow
PacifiCorp, dba Rocky Mountain Power
1407 West North Temple
Suite 330
Salt Lake Ciry, UT 84116
michael.snow@oacifi com.com
Data Request Response Center
PacifiCorp
825 NE Multnomah, Suite 2000
Portland, OR97232
datarequest@paci fi com.com
Dated this l lth day of December, 2018.
Katie Savarin
Coordinator, Regulatory Operations
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