20220817Application.pdf

ROCKY MOUNTAINm,m*.
August 17,2022
VA ELECTRONIC FILING
1407 W. North Temple, Suite 330
Salt Lake city, utah 84116
Idaho Public Utilities Commission
I l33l W. Chinden Blvd.
Building 8 Suit 20lA
Boise,ID 83714
Attn: Jan Noriyuki
Commission Secretary
RE CASE NO. PAC.E-22-12
IN TIIE MATTER OF TITE APPLICATION OF ROCKY MOT'NTAIN POWER
REQTIESTING 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 2020 and202l program years.
lnformal questions related to this matter may be directed to Ted Weston at [phone] or me
at (801) 220-42t4.
Sincerely,
S
Michael S. Snow
Manager, Regulatory Affairs
Enclosures
Emily Wegener, (ISB# I l6l4)
Rocky Mountain Power
1407 West North Temple, Suite 320
Salt Lake Ciry, Utah 841l6
Telephone : [phone]
Email : emilv.wegener@pacifi corp.com
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 )
MAI\AGEMENT EXPENDITURES. )
CASE NO. PAC.E.22.I2
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 yearc 2020 and 2021 in the amount of $10,039,507 as prudently incurred
("Application").
In support of this Application, Rocky Mountain Power states as follows:
l. Rocky Mountain Power is authorized to do and is doing business in the state of
Idaho as a public utility providing retail electric service to approximately 86,500 customers.
Rocky Mountain Power is a public utility subject to the jurisdiction of the Commission
pursuantto Idaho Code $ 6l-129.
2. The Company presents the 2020 and 2021 annual energy efficiency and peak
reduction reports, ("Annual DSM Reportso'), results of program cost effective analyses, and
third-party program evaluations.
APPLICATION OF
ROCKY MOUNTATN POWER
Page I
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. l9l,
Customer Efficiency Services Rate Adjustment ("Schedule l9l"), 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 filed
energy efficiency and peak reduction reports with the Commission for program years 2020 and
2021 under Case No. PAC-E-05-10, and made them available on the Company's website.l'2
These reports followthe format set forth in the MOU and evaluate DSM program performance,
including expenditures, savings and cost effectiveness, as well as the balancing account
activity associated with Schedule l9l.
5. During 2020 and202l,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
customers can also participate in the inigation load management progtam.3 The Company
I 2020 Annual Report:
https://www.pacificorp.comicontent/dam/pcorp/documents/enipacificom/environment/dsm/idaho/2020_ldaho_
Enerey_Effi ciencv_and_Peak_Reduction_Report.pdf22021 AnnualReport:
httos://www.pacificorp.com/content/dam/pcorp/documents/en/pacificorpienvironmenVdsm/idaho/202 l_ldaho_
Enerey_Effi ciencv-Peak-Reduction-Annual-Repon.pd f
3 In 201l, the Irrigation Load Control progrirm 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 MOT'NTAIN POWER
Page2
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 2020 and202l were:
o Schedule 2l - Low lncome Weatherization/Low Income Education ("LIW");
o Schedule I l8 - Residential Energy Efficiency ("Wattsmart Homes")
o Home Energy Reports - not tariffed ("HER"); and
o Schedule 140 - Non-Residential Energy Efficiency ("Wattsmart Business")
PROGRAM EXPENDITURES
7 . The Company requests a Commission determination that the DSM expenditures
totaling $10,039,507, which represents $5,454,714 for 2020 and $4,584,793 for 2021, were
prudent and in the public interest. The expenditures submitted in this Application represent the
activities that took place during program years2020 and202l 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 Annual DSM Reports. For added convenience,the}02D
and202l balancing account activity is provided in Tables I and2 below.
APPLICATION OF
ROCKY MOUNTAIN POWER
Page 3
Month
Monthly
Program Costs
- Fixed Assets
Monthly net
Accrued
Costs
Rate
Recovery
Carrylng
Charge
Cash Basis
Accumulated
Balance
Accrual Basis
Accumulated
Balance
Dec-19 S(1,60s,796)S(1,066,780)
Jan-20 S490,918 s109,692 S(309,946)S(2,s26)5.1,427,34s1 S(8s5,591)
Feb-20 s376.181 sQ32,7081 s(289,51s)s(2,307)s(1,343,090)s(1,045,140)
Mar-20 s334,0s6 S24,6Ls s(2s5,3s4)SQ.L74l s0,267,s621 s(944,997)
Apr-20 s37s,901 S(128,581)sQ24,9491 S(1,987)S(1,118,598)S$24,7L31
May-20 S344,065 s.127,s281 s(282,406)S(1,813)S(1,0s8,7s0)s(992,394)
Jun-20 s338,863 s77,2L8 s(486,648)S(1,888)5{.1,2o8,4241 S(e45,800)
Jul-20 s2s3.481 s108,532 src52.7281 5Q.3471 S(1,610.018)s0.239,7621
Aue-20 s404.810 ss9,780 s(614,320)s(2,8s8)s(1,822,38s)s(1,392.3s0)
Sep-20 sss0,496 S(s7,4s8)sls20,2L4l S(3.012)S(1,795,115)s(1,422,s38)
Oct-20 5487,875 Sssr s(339,2e6)S(2,868)S(1,549,404)517,275,4361
Nov-20 s649,484 SoG,oo4 s(29s,044)SQ,4s4l ${.L,297,4L81 S(8s8,44s)
Dec-20 St.t44,sz6 s4s,388 s(323.126)s(1,478)51477.4971 s6.86s
2020 Totals ss,7s0,6s5 s(s4,5ssl S(4,s94,G4s1 S.27.7t2l
Table I -2020 Schedule 191 Balancing Account Activity
Table 2 -2021Schedule 191 Balancing Account Activity
Month
Monthly
Protram
Costs - Fixed
Assets
Monthly net
Accrued
Costs
Rate
Recovery
Carrylng
Charge
Cash Basis
Accumulated
Balance
Accrual Basls
Accumulated
Balance
Dec-20 477,497 s6,86s
Jan-21 sL97,124 s7,053 s(328.018)s(4s2)s(608.842)S(4s7.336)
Feb-21 s620.139 s(86,623)s(291,561)s(371)s(280,735)s(151,197)
Mar-21 s2s3,994 s54,892 s(270,023)s(241)s(297,00s)s{tr22,s7sl
Apr-2L s390,755 str73,722],sQ4L,222',)s(18s)S(147,5s8)S(146,949)
May-21 s384.649 s33.831 s(307.321)s(91)s(3s,882)
Jun-21 s380,052 5U7,7671 s(s47,489)s(128)s1237,s761 s(281,204)
Jul-21 5297,43s S(25,912)S(768,178)s(3e4)s(709,114)s079,2s31
Aue-21 s23s,s58 s(11,619)s(s92,8s8)s(740)5lt,o67,L44l s(1,148,901)
Sep-21 5647,L40 s8.610 S(4s1,397)s(808)S(94s,3ss)
Oct-21 5362,476 sQ6,9L7l s(33s.288)s(715)s(84s.73s)s(94s.799)
Nov-21 s247,OO4 S(10,s14)s(279.810)s(718)s(879,2s9)s(989,838)
Dec-21 S6ss,37o 5L69,22O S(300,1s1)s(s8s)s(s24,62s)S(46s,984)
2021Totals s4,67L,7L6 s(140,4s7)S(4,713,4161 s(s.429)
APPLICATION OF
ROCKY MOUNTAIN POWER
Page 4
ENERGY EFFICIENCY SAYINGS AND COST EFFECTIVE
9. The annual energy efficiency portfolio savings achieved through the
Company's DSM programs were 25,789 MWh in2020 and 18,692 MWh for 2021, measured
at generation and first-year savings.
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 ("NM"), and Participant Cost Test ("PCT") at the
measure category: program-level, sector-level and portfolio-level. Pursuant to Commission
Order No. 33766, issued May 18,2017, the Company 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.
I l. In2020 and202l, the energy efficiency portfolio as a whole was cost-effective
from the UCT perspective. [n2020, Low Income Weatherization program did not pass the
PTRC, but did pass the PTRC in 2021.4 Table 3 below summarizes the cost effective results
from the 2020-2021 period.
Table 3 -2020 and 2021Cost effective Results
Energr Effrciency Program CostlBenefit Test Type 2020 2A2l
Energy Efficiency Portfolio UCT 1.25 l.68
Wattsmart llomes UCT 0.88 0.99
Home Energy Reports UCT 2.72 10.40
Low Income Weatherization PTRC 0.74 4.31
Wattsmart Business UCT 1.51 r.85
a See Table l0 ofthe 2020 and202l Annual Reports.
APPLICATION OF
ROCKY MOUNTATN POWER
Page 5
ENERGY EFFICIENCY TARGETS
12. Table 4 below 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 the2020-2021 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 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 - Energy Efficiency, Achievable Technical Potential, & IRP Selections
* Potential from20191202l DSM Potential Study and selections from the20191202l IRP
Update
13. As shown in Table 4, from 2020 through202l the Company achieved 36,380
MWh, at generator, of energy efficiency savings in Idaho, equating to 104.6 percent of the
34,780 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.
s Includes first-year savings from the LIW, Wattsmart Homes, and Wattsmart Business programs, and incremental
savings from the FIER program.
APPLICATION OF
ROCKY MOUNTATN POWER
Source ofSavings Idaho MWh Savinss (at penerator)
2020 2021 2020-2021Total
Achievable Technical Potential*28,596 26,857 55,453
Integrated Resource Plan Selections*17,190 17,590 34,780
Energy Effi ciency Portfolio Performances 2t.993 r4"387 36.380
Page 6
PROGRAM EVALUATIONS
14. 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.
15. Process evaluations assess program delivery, from design to implementation, in
order to identi$ efficiencies, including identiffing what worked, what did not work,
constraints, and potential improvements. IdentiSing opportunities for improvement is
essential to making corrections along the way.
16. 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.
17. 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.
APPLICATION OF
ROCKY MOLTNTAIN POWER
Page 7
18. Process and impact evaluations for the Wattsmart Homes 2019-2020,6 Home
Energy Reports 2018-2019,7 and Low Income Weatherization 2016-20178 programs were
published during the 2020-2021 prudency timeframe. The process and impact evaluation for
the Wattsmart Business 2018-2019e program was published in the first quarter of 2022.
MODIFIED PROCEDURE
19. Rocky Mountain Power believes that consideration of the proposals contained
in this Application do not require an evidentiary proceeding, and accordingly requests that this
Application be processed under modified procedure pursuant to RP 201-204, which allows for
consideration of these issues by written submissions rather than by an evidentiary hearing. If
however, the Commission determines that an evidentiary proceeding is required the Company
stands ready to provide supporting testimony.
COMMUNICATIONS AND SERVICE OF PLEADINGS
20. 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 841l6
Telephone : [phone]
Fax: [phone]
Email : ted.weston@pacifi corp.com
em i ly.wegener@pac ifi corp.com
michael.snow@paci fi corp.com
6https://www.pacific
ntain_Power-ldaho-EMV-Report-20 I 9-2020.pdf
7 https://www.pacificorp.com/content/dam/pcorp/documents/en/pacificorp/environment/dsm/idaho/201E-
20 I 9_l D_H ER-Eval uat ion-FINA L-V 3-2020 I 2-0 8.pdf
8 https://www.pacificom.com/content/dam/pcorp/documents/en/pacificorp/environment/dsm/idaho/2016-
I 7_Paci fi Corp_Low_l ncome-Weatherization-Report-lD-FINAL-clean.pdf
e https://www.oacificorp.com/contenUdam/pcorp/documents/en/pacificorp/environment/dsm/idaho/2018-
20 I 9-l daho-WSB-Eval uation-Final.pdf
APPLICATTON OF
ROCKY MOUNTAIN POWER
Page 8
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 (prefened): datarequest@f,acificom.com
By regularmail:Data Request Response Center
PacifiCorp
825 NE Multnomah, Suite 2000
Portland, OR97232
REQUEST FOR RELIEF
21. WI{EREFORE, for the reasons set forth above Rocky Mountain Power
respectfully requests that the Commission approve this Application by: (l) issuing an order
authorizing that this matter be processed by Modified Procedure; and (2) issuing a final order
designating Rocky Mountain Power's 2020 and202l total DSM expenditures of $10,039,507
as prudently incurred.
DATED this l7s Day of August2022.
Respectfu lly submitted,
Emily Wegener
Attorney for Rocky Mountain Power
By
APPLICATION OF
ROCKY MOI.JNTAIN POWER
Page 9