20200828Application.pdf

Y ROCKY MOUNTAIN
FTOWER
A DTVTSTON Or PACTFTCORP
August 28,2020
VU ELECTRONIC FILING
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1407 W. North Temple, Suite 330
Salt Lake city, utah 84116
Idaho Public Utilities Commission
11331 W. Chinden Blvd.
Building 8 Suite 20lA
Boise, lD 83714
Attn: Jan Noriyuki
Commission Secretary
RE:CASE NO. PAC.E-a0-II
IN THE MATTER OF THE APPLICATION OF ROCKY MOUNTAIN POWER
REQUESTING A PRUDENCY DETERMINATION ON DEMAND.SIDE
MANAGEMENT EXPENDITURES.
Please find enclosed for filing in the above captioned matter Rocky Mountain Power's
Application requesting an order designating its demand-side management expenses as prudently
incurred for 2018 and20l9 program years.
For informal questions related to this matter, please contact me at [phone].
Sincerely,
-/Ws
Michael S. Snow
Manager, Regulatory Affairs
Enclosures
Emily Wegener, (admitted pro hac vice)
Rocky Mountain Power
1407 West North Temple, Suite 320
Salt Lake Ciry, Utah 84116
Telephone: [phone]
Email: [e-mail]
Attorneyfor Roclqt Mountain Power
BEFORE THE IDAHO PUBLIC UTILITIES COMIVTISSION
IN THE MATTER OF TIIE APPLICATION )
oF ROCKY MOUNTAIN POWER )
REQUESTING A PRTIDENCY )
DETERMINATION ON DEMAND.SIDE )
MANAGEMENT EXPENDITURES. )
CASE NO. PAC.E.aO.TI
APPLICATION
COMES NOW, Rocky Mountain Power, a division of PacifiCorp (the "Company"), in
accordance with Order No. 32788 and Rule of Procedures 052 and 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") expenditures for
program years 2018 and 2019 in the amount of $9,634,576 as prudently incurred
("Application").
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 84,000 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 Idaho pursuant to Idaho Code g 6l-129.
2. The Company presents the 2018 and20l9 annual DSM reports, ("Annual DSM
Reports"), results of the programs cost effective analysis, and third-party program evaluations.
APPLICATION OF
ROCKY MOUNTAIN POWER
Page I
BACKGROIIND
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 Effrciency Services Rate Adjustment ("Schedule 191"), which was applied to
customers' bills beginning May 1,2006.
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 DSM and peak reduction reports with the Commission for program years 2018
and 2019 under Docket No. PAC-E-05-10, and made them available on the Company's
website.l'2 These reports follow the format set for*r in the MOU and evaluate DSM program
performance, including expenditures, savings and cost effectiveness, as well as the balancing
account activity associated with Schedule 191.
5. During 2018 and 20l9,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
I 2018 Annual Report:
https://www.pacificorp.com/content/dam/pcoro/documents/en/pacificorp/environment/dsm/idaho/201S-ID-DS
M-Annual Report Appendices.pdf.
2 2019 Annual Report:
https://www.pacificorp.com/content/dam/pcom/documents/enlpacihcorp/environment/dsm/idaho/2019_ID_DS
M_Annual Reoort 4-20-20.pdf.
APPLICATION OF
ROCKY MOUNTAIN POWER
Page2
customers can also participate in the irrigation load management program.3 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 energy efficiency programs subject to Schedule l9l in 2018 and 2019 were:
o Schedule2l - Low Income Weatherization/Low Income Education;
o Schedule I l8 - Home Energy Saver ("Wattsmart Homes")
o Home Energy Reports (no tariff); and
o Schedule 140 -Non-Residential Energy Efficiency ("Wattsmart Business")
PROGRAM EXPENDITURES
7 . The Company requests a Commission determination that the DSM expenditures
totaling $9,634,576, which represents $4,766,097 for 2018 and $4,868,479 for 2019, were
prudent and in the public interest. Expenditures by category are provided in the accompanying
Appendix 2 of the Annual DSM Reports. 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 the activities that took place during program years 2018 and 2019
through a year-end cost true-up process.
3 In 2011, 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 MOUNTAIN POWER
Page 3
8. The Company reports its Schedule 191 balancing account quarterly to
Commission Staff, and annually inthe Annual DSM Reports. For added convenience, the 2018
and2019 balancing account activity is provided in Tables I and2 below.
Table 1 - 2018 Schedule 191 Account
Itllonth Rrtr R*ovrry
Crlh Bab
Aermulrtcd
Balence
Table 2 -2019 Schedule 191 Balancing Account Activity
Monthhil.t
Accucd Coctr
APPLICATION OF
ROCKY MOI.INTAIN POWER
AsudBsb
Aermuhrd
ECmo
irlonthh
Progrm C;octr-
Ftred A*rtr
Crrying
Chrgc
s (1,326,350)s(1,127,25t1Dec-17
Jan-18 s 201,220 S ta,765 s (346,807)s (1,166)s (1,473,103)s(1,2s923e1
s (313.s21)S (1,273)s u,s83,s921 s(1,289,160!Feb-18 S zoa,sos S 80.s68
$ 49O,7L7 s (55,6951 I (309,063)$ (t,zaal s (1,403,182)S(1,155,445)Mar-18
Apr-18 S 2s2,5s8 s (1s,3s4)s (274,s98)s (1,178)5 (1,426,30U s{1,207818}S rla,ezr S (307.626)S (1,223)s (1,s09,4s4)5{1,1s2,4s0}May-18 s 225,596
s (85,770)S (s08,443)s (1,2es)5 (1,s99,330)s{1,328,097)s 419,862
s 319,289 S ros,zsa s (782,161)S (1,s26)s (2,063,728)5{1,68s,740}Jul-18
Jun-18
Aug-18 s 537,997 s (64,187)S (58s,852)S (r,783)s (2,217,355)s{1,903,555)
5 327,674 S s.rge 5 (ssz,rzql S (1,s4r)$ (2,444,007)s(2,12s,013)Sep-18
Oct-18 s 389,982 s (5s,ess)S (384,812)S (2,o3sl s (2,440,873)s(2,191,835)
5 317,0s7 S (317,304)s (2,006)s (2,374,69s)s(1,808,600)Nov-18 5 38s.488
$ ez+,rze S (248,947)s (3ss,881)5 (1,763)s (1,858,213)S(1,541,064)Dec-18
2018 Totah $ 4,629,a12 $ u8,oso 5 15,I.42A421 s (1814331
Month
fbnthly
Plotr.mCo*r-
fDad Alr*t
monthly il.t
Amrucd Go*r Rrtr Rrcovrry Crrrylng
Chr3r
drEd.
Accumuhed
tjrnce
AccrurlE*
Accumuhtrd
Sdrnrr
18-Dec s {1,8s8.2131 s 11,s41,054)
19-Jan s 349.549 s 63.705 s l3s8.s84t s l3.10sl s 11.870.3s31 s 11.489.4991
19-Feb s s32.542 s 54,W s 1331,929)s (2,9s01 s (1.672,5901 s (1,237,3321
19-Mar s 474.350 s (40.7351 s 1283.372)s (2,5281 s (1,'184.2291 s (1,089,706)
19-Apr 5 404,631 s (76.0841 s 1224.5671 s (2.3241 s 11.306.5901 s {988.1s1t
19-May 5 343.792 s 137.4261 5 1277.6711 s (2.1231 s (1.242.s931 s (961.s801
19-Jun s 244.759 S 234,955 S (39s.8s2)s (2.197)s (1.39s,882)s (879.9141
19-Jul 5 277,223 s 9.491 s l6s6.s93l S (2,648)s 11.783.9001 s (1.258.4411
19-Aus s 625.460 s 1t72.3231 s 1609.162)s (2.9s91 s (1.769.s611 s (1.416.4261
19-Seo s 338.018 s (s.387)S (491.067)s (3,0771 s (1,92s,6871 5 (1,s77,9381
19-Oct s 296.698 s 64.218 s 1281.124t s (3.196)s 11.913.3081 s 11.s01.342)
19-Nor,s 165.183 s 185.798 s (284,803)
s (286.226)
s (3.2881 s (2.03s.2171 s {1.437.4531
19-Dec s 718.679 s (s8.748)s (3.0321 s (1.60s.7961 s {1.065,780)
2019 Tot.l s 4.766,994 s 221,fi7 S l4,4El,osol 3 (33,s271
Page 4
ENERGY EFFICIENCY SAVINGS AI\D COST EFFECTIVE
9. The arurual energy efficiency portfolio savings achieved through the
Company' s DSM programs were 17,663 MWh in 20 1 8 and 21,3 54 MWh for 2019, measured
at the customers' meter.
10. The Company examines its programs from all cost effective tests, including the
PacifiCorp Total Resource Cost (*PTRC"), Total Resource Cost ("TRC"), Utility Cost Test
("UCT"), Ratepayer Impact Measure ("KM"), and Participant Cost Test ("PCT") at the
measure category: program-level, sector-level and portfolioJevel. Pursuant to Commission
Order No. 33766, issued May 18, 2017, the Company now uses the UCT as the primary
determinant for cost effectiveness. However, the Low Income Weatherization program still
uses the PTRC test authorizedby Commission Order No. 32788, issued April12,2013.
1 1. In 2018, the energy efliciency portfolio as a whole was only cost-effective from
the PCT perspective. On an individual program level however, the Waffsmart Homes and
Wattsmart Business programs passed the UCT.a The Home Energy Reports program also
passed the UCT if the one-time start-up costs of establishing a new progrilm administrator are
excluded.s The Low Income Weatherization program passed the PTRC.6 It is also worth noting
that cost effectiveness in general was adversely impacted by the reduction in avoided costs
from the 2017lntegrated Resource Plan ("IRI";.
12. ln 2019, the energy efficiency portfolio was cost-effective from the UCT
perspective.T On an individual program level, the Wattsmart Homes, Home Energy Reports,
a See Tables 8 and l7 ofthe 2018 Annual Report.
5 See Tables 9 and 10 ofthe 2018 Annual Report.
6 See Table 12 of the 2018 Annual Report.
7 See Table I ofthe 2019 Annual Report.
APPLICATION OF
ROCKY MOUNTAIN POWER
Page 5
and Waffsmart Business programs all passed the UCT, and the Low Income Weatherization
program passed the PTRC.8 Table 3 summarizes the cost effective results from 2018 and,2Ol9
discussed above.
Table 3 - 2018 and 2019 Cost effective Results
Energy Efficiency Program Cost/Benefit Test Type 2018 2019
Energy Effi ciency Portfolio UCT 0.94 1.09
Wattsmart Homes UCT l. r3 l.l1
Home Energy Reports
UCT
(with startup costs)0.82 N/A
UCT
(without startup costs)l.86 2.03
Low Income Weatherization PTRC 1.39 1.13
Wattsmart Business UCT 1.04 r.25
ENERGY EFFICIENCY TARGETS
13. 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 2018-2019 period. 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 effrciency resources. Absent the achievability assumption and ramp rates, all
discretionary resources (those that can technically be acquired at arry time) would be available
at the start of the planning period, which is unrealistic from both a planning and acquisition
standpoint.
8 See Tables 8, 9, 11, and 16 ofthe 2019 Annual Report.
APPLICATION OF
ROCKY MOUNTAIN POWER
Page 6
Table 4 - Energy Efficiency, Achievable Technical Potential, & IRP Selections
* Potential from20l7 DSM Potential Study and selections from 2017IRP Update
14. As shown in Table 4, from 2018 through2019 the Company achieved 43,264
MWtt, at generator, of energy efficiency savings in Idaho, equating to 94 percent of the 46,010
MWh selected by the IRP. 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 effective of its energy efficiency
programs through validation of energy savings and to provide information to assist in program
management.
16. Process evaluations assess program delivery, from design to implementation, in
order to identify efficiencies, including identifying what worked, what did not work,
constraints, and potential improvements. Identiffing opportunities for improvement is
essential to making corrections along the way.
APPLICATION OF
ROCKY MOLINTAIN POWER
Page 7
Source of Savings Idaho NIWh Savinss (at senerator)
2018 2019 2018-2019 Total
Achievable Technical Potential*32,765 35,r93 67,958
Intesrated Resource Plan Selections*22.950 23,060 46,010
Enersy Efficiency Portfolio Performance 19,59s 23.669 43,264
17 . Impact evaluations determine the impacts (e.g. energy and demand savings) that
directly result from a program. They also support analyses of cost effectiveness 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. Process and impact evaluations for the Wattsmart Homes 2017-2018e and
Wattsmart Business 2016-201710 programs were published during the 2018-2019 prudency
timeframe. Process and impact evaluations for the Low Income Weatherization 2016-2017,
Wattsmart Business 2018-2019, and Home Energy Reports 2018-2019 programs are currently
underway, and all three are anticipated to be published by the first quarter of 2021.
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.
ehttps://www.pacificorp.com/content/dam/pcom/documents/en/pacificorp/environment/dsm/idaho/wattsmart H
omes-Proeram Evaluation-201 7-201 8.pdf.
r0 https://www.pacificom.com/content/dam/pcorp/documents/en/pacificorp/environment/dsm/idaho/2016-
2017 Idaho WSB Evaluation.pdf.
APPLICATION OF
ROCKY MOUNTAIN POWER
Page 8
2t.
COMMUNICATIONS AI\D SERVICE OF PLEADINGS
Communications regarding this Application should be addressed to
Ted Weston
Emily Wegener
Michael S. Snow
1407 West North Temple, Suite 330
Salt Lake City, Utah 84116
Telephone: [phone]
Fax: [phone]
Email: [e-mail]
emily. wesener@pacificorp. com
michael. snow@pacifi corp.com
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@f acifi corp.com
By regular mail Data Request Response Center
PacifiCorp
825 NE Multromah, 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 2018 and 2019 total DSM expenditures of $9,634,576
as prudently incurred.
APPLICATION OF
ROCKY MOUNTAIN POWER
Page 9
DATED this 28e day of August,2020
Respectfully submitted,
By
Emily Wegener
Attorney for Rocky Mountain Power
APPLICATION OF
ROCKY MOI.JNTAIN POWER
Page 10