20111028Comments.pdf

Brad M. Purdy
Attorney at Law
BarNo. 3472
2019 N. 17th 81.
Boise, ID. 83702
[phone] (Land)
[phone] (Fax)
Attorney for Petitioner
Communty Action Parership
Association of Idao
RECEIVED
201 f OCT 28 PH 3: 50
,
Ul~:L¡j
BEFORE THE IDAHO PUBLIC UTILITIES COMMSSION
IN THE MATTER OF TI APPLICATION OF
ROCKY MOUNTAI POWER SEEKIG
AUTORIZATION TO SUSPEND FUTU
PROGRA EVALUATIONS OF SCHEDULE 21,
LOW INCOME WEA TIRIZA TION SERVICES
FOR INCOME QUALIFYIG CUSTOMERS
)
) CASE NO. PAC-E-II-13
)
) COMMTY ACTION
) P ARTNRSllP ASSOCIA-
) TION OF IDAHO'S
) COMMNTS
)
)
COMES NOW, the Communty Action Parership Association of Idaho (CAPAI)
by and though its attorney of record, Brad M. Pudy, and hereby submits the following
comments regarding the Application of Rocky Mountain Power (Rocky Mountain, RM,
Company) in this case pursuant to Commission Order No. 32363 issued September 27,
2011.
I. BACKGROUND
On, April 29, 2011, Rocky Mountain fied an application seeking authority to be
relieved from any fuher obligation to conduct cost-effectiveness evaluations of its Low-
Income Weatherization Assistace Progr (LIWA) on the basis that the LIWA program
is not cost-effective making fuer evaluations wasteful, and seeking a ruling that the
CAP AI COMMNTS 1
Commission approve LIWA as a continuing component of the Company's overall DSM
portfolio.
In support of its contention, RM included with its Application a study conducted
by a third par contractor known as "The CADMUS Group, Inc." (CADMUS) which,
using data input though a computer model based on program "activities for the period
2007 through 2009, purorts to measure the cost-effectiveness ofRM's LIWA program.
The CADMUS study proclaims that Rocky Mountain's curent program is not cost-
effective based on traditional evaluation methodologies and criteria. In spite of the
alleged fact that LIWA is not cost-effective, Rocky Mountain requests that "the
Commission acknowledge the progr as an acceptable par of Rocky Mountain Power's
(DSM) program portfolio, and find that it should continue." Application at p. 4.
In further support of its Application, RM states: "in an effort to reduce future
administrative costs associated with ths program (i.e., cost of obtaing thd par
effectiveness evaluations) Rocky Mountain Power respectfully requests that the Idaho
Public Utilties Commission remove any futue obligation for program evaluations of the
Low Income Weatheriation Services Optional for Income Qualifying Customers
Program (i.e., LIWA)." ¡d. The Company submits that although its overall portfolio of
DSM resources is cost-effective, LIW A is not.
Rocky Mountain furter argues that the recent increase in anual fuding for the
program from a total of $150,000 to $300,000 ordered by the Commission in Order No.
32196 issued on Februar 28, 2011 in Case No. PAC-E-I0-07 (RM's 2010 general rate
case) as well as an increase in the percentage of Rocky Mountain's share of fuding anyCAP AI COMMS 2
given LIW A project from a cap of 75% to 85% have exacerbated the degree to which
LIW A is not cost-effective.
On June 30, 2011, the Commission issued Order No. 32284 ruling that the
Company's Application would be handled under modified procedure pending the
objection of any person to such procedure and invited comments filed withi niety (90)
days (September 28, 2011). Pusuant to agreement of all paries, the Commission
extended the comment deadline to October 28, 2011in Order No. 32363.
On June 22, 2011, CAPAI filed a Petition to Intervene in this proceeding which
was granted by the Commission in Order No. 32286 issued July 1, 2011. Only Staff and
CAP AI are specifically named paricipants to this proceeding at the present time. As wil
be explained below, CAPAI does not necessarly object to modified procedure but, due to
the very unique nature of the Company's request and the timing in which this case is
being processed, it might well be advisable to defer a final ruling on whether a technical
hearing wil be conducted in this casel until the Commssion and all parties have had
ample opportnity to review the nature of the comments filed in response to RM's
application. CAP AI makes a more defintive procedural proposal later in these
comments.
II. CADMUS EVALUATION
The CADMUS evaluation fied in support ofRM's application is based on a
"web-based" computer modeL. Durig the course of analyzing the Company's
application, it became obvious that Staff and CAP AI would need access to the model
i IDAPA 31.01.01.021-400.
CAPAICOMMNTS 3
used by CADMUS to conduct its evaluation as well as specific input data to that model
and the assumptions on which both the model operates and the input data was based. In
addition, CAP AI submitted an extensive set of discovery requests.2 Staff submitted
discovery requests as well and an on-line "webinar" teleconference was conducted in
mid-October involving Rocky Mountain, Staff, CAP AI and CAP AI's exper, Roger
Colton, as well as certin CADMUS personnel familar with the modeL.
The CADMUS personnel who actully performed the model rus and who
interacted with RM regarding the input data weren't all involved in the webinar
resulting in a number of unanswered questions to which RM submitted a cerin degree
of follow-up response, though much later than expected. It was informally agreed that a
second on-line teleconference involving the same paries and possibly additional
CADMUS and RM personnel should be conducted. For reasons unown to CAPAI,
this second teleconference never occured.
III. CAPAI'S POSITIONS
CAPAI emphasizes the magnitude of Rocky Mountain's filing which has had a
profound impact on a substatial percentage of the issues CAP AI has raised since its first
intervention before the Commission nearly a decade ago. In many ways, RM's filing
has become the single most importt case that CAP AI has paricipated in. The reasons
for this are severaL. First, if the CADMUS evaluation is legitimate and accurate and
Rocky Mountain's conclusions' are meritorious, the continued existence of not only that
2 Rocky Mountain's discovery responses were supplemented on numerous ocasions. Collectively, the responses
are very volumous. CAP AI wil serve them on the Commission and all pares via electronic trmission.
CAPAICOMMENTS 4
utilty's LIWA program is in serous jeopardy, but so are the low-income weatherzation
programs of Idaho Power and A VISTA. In fact, a study similar to that conducted by
CADMUS could argubly be used to eliminate every program for every utilty that is
specifically directed to low-income customers.
A. Applicable Law
The most obvious reason for this is that one could argue that the Commission does
not have the legal authority to approve futue fuding increases for low-income
programs, approve the creation of new low-income programs, or even to allow for the
continued existence of curent low-income programs, if those progr are deemed to
not be "cost-effective." It is doubtful that programs deemed not cost-effective wil be
deemed prudent. The Commission is, of coure, a governental agency created by the
Idao Legislatue3 and whose powers and responsibilties are largely set fort in Titles 61
and 62 of the Idaho Code, as are the obligations of public utilties. Of the many statutes
contained in those titles, several are of paricular importce in regard to RM's filing.
First, regarding the duties and obligations of public utilities, Idaho Code Section
61-30 1 states that all charges imposed by a public utilty must be ''just and reasonable."
Idaho Code Section 61-303 provides that all rules and regulations ofa utilty affecting its
rates and charges must be ''just and reasonable" and, fmally, Idao Code Section 61-315
states that no public utilty, in terms of its "rates, charges, service, facilties, or in any
other respect" may grant to any customer any "preference or advantage" or subject any
customer to "prejudice or disadvantage." The statute fuer states that "no public utilty
3 Idao Code Secon 61-201.
CAPAICOMMNTS 5
shall establish or maintain any uneasonable difference as to rates, charges, serice,
facilties or in any other respect either as between localities or as between classes of
service."
CAP AI firy believes that Rocky Mountain's LIW A progr is extemely cost-
effective. Furhermore, it is subject to debate whether implementing a low income-
specific program that provides some form of benefit to low-income customer necessarly
constitutes discrimination, advantage or preference "between localities" or "between
classes" as stated in I.C. Section 61-315. Even iflow-income programs are deemed
subject to the anti-discriination prohibitions ofI.C. Section 61-315, CAPAI assert that
the benefits to other customers of providing low-income assistace offsets any preference
given low-income customers eliminating any potential for tre discriination.
Regardless, the fact remains that the costs of installing weatherization measures in the
households of low-income customers are passed on to other utilty customers. This is
where the duties imposed by Title 61 of the Idaho Code on the Public Utilties
Commission come into play.
The overarching mandate to the Commission regarding the approval of utilty rates
and charges is found in I.C. Section 61-502 which basically requires that the Commission
examine all public utilties' rates and charges to ensure that they are not "unjust,
unreasonable, discriminatory or preferentiaL." In makg this assurance, the Commission
"shall determine the just, reasonable or suffcient" rates and charges of a public utilty
and adjust them as necessar to meet the foregoing parameters.
CAP AI COMMNTS 6
B. Rocky Mountain's Application Would Result in Appealable Order
When CAPAI first received notice ofRM's filing in this case and reviewed the
Application, it was immediately apparent that the filing would create a tremendously
awkward dilemma for the Commssion, Staff and CAP AI. CAP AI is and has been for
some time aware of the fact that Staff desires to have greater clarty and specificity in
how to evaluate the effectiveness of low-income weatherization programs for all three
major electrc utilties. CAPAI's position has consistently been to agree with what it
believes is Staffs position that LIW A should not be exempt from any tye of
effectiveness evaluation and to work collaboratively with Staff and the electrc utilties to
craft an evaluation methodology that is fair to all interests and that taes into
consideration the highly unique characteristics of programs such as LIW A.
The dilemma created by Rocky Mountain's application is that the Company is
simultaneously askig the Commission to fmd that LIWA is not cost-effective, but to
allow it to continue to be par of the Company's overall DSM portfolio. Based on
applicable law as outlined above, this places the Commission in a legally tenuous
position. If the Commission approved Rocky Mountain's application as it is worded, this
would arguably lead to a final order that could be reversed on appeal due to its failure to
comply with anti-discrimination statutes. RM chose what CAP AI considers a highly
unusual maner in which to frame its application, effectively asking the Commission to
reach a questionable ruling.
Because of the awkwardness created by Rocky Mountain's filing, and the fact that
the Company had submitted what on its face was a detailed evaluation performed by anCAPAICO~TS 7
independent third par that purortedly showed LIW A to not be cost-effective, CAP AI
was placed in a very unusual and diffcult position. Rocky Mountain's application alone
creates the dilemma outlined above. Combining the nature of the filing with the timing
and processing of the filing, as discussed below, exacerbates that dilemma.
c. CADMUS Evaluation Untimely
In this regard, and as a brief aside, it should be noted that in Rocky Mountain's
2010 general rate case, Staff noted that the Company was considerably delinquent in
filing a cost-effectiveness of its LIW A program. This was tre as of the issuace of Final
Order No. 32196 in the 2010 general rate case, issued in Februar of ths yea. RM was
under an obligation, pursuant to a Memorandum of Undertading, executed by the
Company on December 22, 2009, to file a "prudency evaluation" of its DSM programs,
including LIW A. By waiting until April of this year to file its long-overdue evaluation,
Rocky Mountain created a problematic procedural scenaro.
D. Protracted Scheduling of Case Exacerbated Dilemma
Upon learing ofRM's fiing, CAPAI began inquirg as to when the case would
be noticed and under what procedure. For reasons unown to CAP AI, the intial Notice
of Application was not issued until the last day of June, more than two months after it
was fied. The reason that this exacerbated the dilemma is that, as CAP AI and many
others were keenly aware at the time RM's filing was made in this case, Rocky
Mountain, Idaho Power, and A VISTA were going to file general rate cases in late
Spring/early summer of this year. CAPAI had firm plans to, and in fact did, interene in
all three of those rate cases. CAP AI feared that if Rocky Mountai's LIW A ApplicationCAPAICOMMNTS 8
were not quickly resolved, it would create a substatially serious problem in light of the
fact that CAP AI intended to seek funding increases for all thee electrc utilties' LIW A
programs in the general rate cases. Having a case pending that called into question the
very legality of LIW A on the whole made the prospect of advocating for LIW A fuding
increases challenging to say the least.
Furthermore, CAPAI knew that Idaho Power and A VISTA were aware of Rocky
Mountain's LIWA filing when they filed their rate cases. T the simultaneous pendency
of the LIW A case made those two utilties hesitat to agree to fuding increases pending
resolution of the LIW A case. CAP AI had reason to believe that at least one of those two
utilties intended to not propose additional LIW A fuding pending the outcome of the
Rocky Mountain application. In fact, none of the three utilties proposed or have thus far
agreed to LIW A fuding increases. CAP AI correctly assumed that there would be a
"domino" effect of all ths. Though CAP AI canot divulge anyting discussed durng
any settlement negotiations, it is obvious that the fact that the Rocky Mountain case
would not be resolved until late 2011 or even sometime into next year might have caused
hesitation on the par of some to support LIW A fuding increases especially given the
possibilty that a LIW A progr might ultimately be deemed not prudent.
While it might be tempting to dismiss this dire scenaro as overreaction, it has
proven out so far. The comment period in this case was set for September 28, 2011.
Although all paries to this case supported extending the comment deadline by one month
due to the complexity and inaccessibilty of the CADMUS web-based model, Staff
noticed up settlement negotiations for all thee pending electrc rate cases weeks if notCAP AI COMMENTS 9
months prior to the original September 28 deadline. This forced CAP AI to enter
settlement negotiations without any sense of whether the Commission would ultimately
deem one of Idaho's thee LIW A programs to be prudent. CAP AI has already pre-filed
testimony in the Idaho Power case and wil soon file in the Rocky Mountain rate case.
Although CAP AI did sign the settlement agreement with A VISTA, it did so based
on the fact that A VISTA was fuding its LIW A program at a rate more than 200%4
greater than Idao Power and roughly 25% greater than Rocky Mountain. Ths basis for
CAPAI's agreement to settle is set fort in the testimony ofTeri Otens (later converted
to comments) submitted in the A VISTA case. But, as a quick review of the recent
settlement agreements executed by certin paries in the Idaho Power and Rocky
Mountain Power cases makes obvious, CAP AI declined to join in those settlements and
intends to fully proceed to hearg on numerous issues including LIW A fuding. It is no
stretch of logic to contend that the late filing of Rocky Mountain's application and the
somewhat protracted scheduling of this case caused the procedural conundrm described
above. This scenaro has also thown CAPAI's primar objective (LIWA) into a far
more contentious posture.
It is wort noting that although CAP AI often weigh in on numerous issues not
related specifically to low-income weatherization, LIWA programs are curently the meat
of CAP AI's typical involvement in proceedings before this Commission. The
Commission is well aware that CAP AI continues to seek a form of bil assistace similar
to that allowed in most if not all other wester state and in many states nationwide. Until
4 Idao Power's fudig alone must be incred by $1.5 millon to equal A VISTA fudig on a per capita basis.
CAP AI COMMTS 10
then, CAP AI continues to do everyg within its limited resources to advance the
interests of utilties' low-income customers and, in the process, provide benefits to all
ratepayers.
Furermore, as evidenced by the testimony ofTeri Ottens curently filed in the
Idaho Power general rate case, CAP AI is addressing numerous issues that to some extent
affect all customers, paricularly the residential class. It would not be uneasonable to
state that CAPAI is curently the closest thing that the state of Idaho has to a consumer
interest energy advocate. CAP AI makes this asserion with due humilty but in
recognition of the simple trth. Thus, the unfortate natue of Rocky Mountain's filing,
the timing of that filing, the timing of scheduling the case and the reaction of other paries
to the filing have made what was already a critical case to CAP AI even more so.
IV. CAPAI'S RESPONSE TO CADMUS STUDY
Realizing the significance and possible implications of the CADMUS study,
CAP AI retained an expert consultat highly traied and specialized in its abilty to
evaluate the effectiveness of public utilty low-income weatherization programs.
CAPAI's expert in this case is Mr. Roger Colton of the fir "Fisher, Sheehan & Colton,
Public Finance and General Economics." Mr. Colton's resume is attched hereto as
Exhibit "A," establishing his expertse in this field.
Also attched hereto as Exhibit "B" is Mr. Colton's analysis of the CADMUS
study. Prior to preparng his analysis, Mr. Colton was provided all relevant materials in
this case and paricipated in the on-line teleconference with RM, CADMUS, Staff and
CAPAICOMMNTS 11
CAP AI and, consequently, has more than ample factul knowledge and basis for his
opiD1ons.
Mr. Colton's analysis provides, in explicit detail, a listing of the many aspects of
the CADMUS study that constitute "fatal flaws" renderig the conclusions derived from
the study highly inaccurate and misleading. These flaws involve both the maner in
which the web-based model utilzed by CADMUS was used as well as the data that were
input though the model, or lack of data. Mr. Colton explais with precision how these
flaws affect the CADMUS study's conclusions and the cumulative effect they have on
the ultimate conclusion of whether Rocky Mountain's LIWA progr is cost-effective.
As Mr. Colton notes, even if the highly inaccurate results produced by CADMUS, with
one or two adjustments, were accepted at face value, the LIW A program is stil cost-
effective with an appropriate margin of error. The correction of the many flaws
contained in the study all increase the program's cost-effectiveness. When combined,
there can be no doubt that the program is cost-effective.
A noteworthy point is that, while the societal benefits produced by programs such
as LIW A are impossible to deny (e.g., reductions in homelessness and crime, improved
living conditions for the poor, etc.), no attempt is made to quantify them by any par to
this proceeding thus far. The fact is that the program provides tagible economic benefits
to the entire Rocky Mountain system and to all customers that more than offset the costs
of the program. Rocky Mountain's contention that the recent $150,000 increase in
fuding diminishes cost-effectiveness rests on the presumption that the program is a
money-loser. If, as Mr. Colton concludes, the program provides net benefits, then
CAPAICOMMNTS 12
additional fuding has the opposite effect. This trism applies equally to the 10%
increase in RM's fuding sharg percentage of each LIWA project.
Regarding Rocky Mountain's request to be relieved of its obligation to evaluate
LIWA CAP AI, though confident that the program is very cost-effective, agrees with
Staffs position that Rocky Mountain's request be denied. There is no logical reason to
exempt a low-income weatherization program from any and all analysis, especially
considering that program costs are borne by ratepayers other than program paricipants.
CAP AI submits, however, that LIW A is a DSM program unique from all others.
Consequently, many of the program benefits fall outside the traditional DSM cost-benefit
evaluation methodologies. Examples of such benefits include reduced arearages,
disconnections, and bad debt wrte-offs.5 Though the CADMUS study fails to properly
calculate and value these benefits, it appears that even Rocky Mountain does not dispute
that they should legitimately be included in evaluating LIW A. Thus, any final conclusion
regarding the cost-effectiveness of a given LIW A program should include the tye of
valuation/calculation of these "non-energy" benefits as set fort in Mr. Colton's analysis.
Finally, regarding Rocky Mountain's request that it be allowed to forgo any futue
evaluations of LIW A due to the cost of paying a third par contrctor to perform
independent evaluations, CAP AI notes that the CADMUS study does not seem to include
the costs RM paid to CADMUS. CAP AI was not a par to the proceeding in which the
varous utilties agreed in a Memorandum of Understading to conduct cost-effectiveness
evaluations of their DSM programs using independent contractors. Consequently,
5 Referred to by CADMUS as "non-energy" benefits.
CAPAICOMMNTS 13
CAP AI does not take a paricular position on whether the MOU should be modified for
LIW A. It seems somewhat intuitive, however, that once an acceptable methodology is
agreed upon, the costs of evaluations should be less in subsequent years. Regardless,
CAP AI points out that it is diffcult to know the impact that the cost of such evaluations
has on cost-effectiveness if that cost is not identified by the Company.
To summarize, CAPAI agrees with Rocky Mountain's request that LIWA
continue to be a par of the Company's DSM portfolio, but disagrees that LIWA should
be entirely exempt from any tye of evaluation.
V. CAPAI'S PROCEDURA RECOMMENDATIONS
Because CAP AI has invested considerable resources in paricipating in this case
and, hopefully, providing Staff with a solid staring point from which to derive an
acceptable cost-effectiveness evaluation methodology, it would be counter-intuitive to
star entirely anew. As Mr. Colton posits in his analysis, there is nothing inerently
wrong with the web-based model used by CADMUS. It was the maner in which that
model was used and the data input that must be corrected or rejected. If Mr. Colton's
critiques and suggestions were followed, it would not involve much additional work to
set up the proper methodology.
CAP AI realizes that Rocky Mountain, and perhaps Staff, wil want to respond to
Mr. Colton's analysis and that such a response taes time, especially under the curent
caseload all paries are dealing with. What CAP AI believes critical is that the flawed
CADMUS study not be used as a basis for any par, including Staff, to not support
increases to LIW A funding or to allow any backsliding from the efforts made by CAP AICAPAI COMMNTS 14
in this case. CAPAI believes that the failure to timely resolve RM's application in this
case has caused Staff and other paries to not support the LIW A fuding increases that
CAP AI is currently seekig in the two remaining electrc rate cases. Just this year, the
Commission approved a fuding increase for Rocky Mountain's LIWA program in the
2010 rate case that exceeded the amount of increase sought by CAP AI. The Commission
based its ruling on Staffs proposed higher amount. 6 It would be unfortate to allow
what has clearly been demonstrated to be a fatally flawed study to stop otherwise
legitimate fuding increase requests.
LIW A fuding increases have been found prudent and approved by this
Commission for all thee electrc utilties for the better par of the past decade. CAP AI
has consistently proven that there continues to be a substatial gap between the need for
LIWA and available resources creating a large backlog and impossibly long waiting lines
for eligible LIW A customers. CAP AI assumes that the Commssion has taen this fact
into account over the past years when it has approved LIW A fuding increases and
program design changes. Though CAP AI acknowledges that the Commission has been
very supportive ofLIWA, the thee progrs in Idao are not exactly flush with money.
The gap between need and resources is widening as economic conditions continue to
worsen. CAP AI recommends, therefore, that the Commssion approve Rocky
Mountain's request that LIW A continue to be par of the RM DSM portfolio, but deny
the request to cease furter evaluations, leaving open the extent and maner in which
futue evaluations should be conducted.
6 Case No. PAC-E-ll-13, supra.
CAPAICOMMNTS 15
In order to prevent this case from serving as a reason to not support or approve
future LIW A fuding increases for all utilties, CAP AI submits that a fmal resolution
should be made by the Commssion in the near future. Pushing ths case into
collaborative workshops to be conducted sometime in the future would create continued
uncertinty and unnecessarly stall much needed fuding increases, including the $1.5
milion by which Idaho Power must increase its fuding to equal A VISTA on a per capita
basis. Thus, CAP AI proposes that a reasonable period of time be established for Staff
and Rocky Mountain to respond to CAPAI's position. After receiving such responses,
the Commission could then issue a final order in ths matter.
VI. CONCLUSION
Rocky Mountain's application should be granted in par, and denied in par as set
forth above. The CADMUS study is obviously inaccurate and misleading. Mr. Colton's
analysis demonstrates that Rocky Mountain's LIWA program is clearly cost-effective and
prudent. Procedurally, the Commission should set a deadline for responses to CAPAI's
position and then make a determination fmally resolving the case so that the CAP
agencies who implement LIW A can continue to provide vital services to the poor that
result in benefits to all customers. Finally, Staffis entitled to some definitive guidace
on what it should reasonably expect from the utilties in terms of effectiveness
evaluations in the future.
CAPAICOMMNTS 16
DATED, this 28th day of October, 2011.
CAP AI COMMNTS
ß:~~LBrad M. Purdy
17
CERTIFICATE OF SERVICE
I, the undersigned, hereby certify tht on the 28th day of October, 2011, I served a copy of
the foregoing document on the followig by electronic trmission.
Ted Weston
Rocky Mountain Power
201 South Main, Suite 2300
Salt Lake City, UT 84111
Danel E. Solander
Rocky Mountan Power
201 South Mai, Suite 2300
Salt Lake City, UT 84111
Neil Pnce
Idaho Public Utilties Commission
Deputy Attorney General
472 W. Washington S1.
Boise,ID 83702
Jean Jewell
Commission Secreta
Idao Public Utilties Commission
472 W. Washigton St.
Boise,ID 83702
DATED, ths 28th day of October, 2011
~s2çf
Bra M. Pudy
CAPAICOMMNTS 18
EXHIBIT A
RE":CEl\/F:D
--,
Colton Vitae--Page i
?fll i. O.r"'i' 'ìq pv 3: 50L.vJ' v c,-, ii
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: l "'t'"'. ~ ;' ¡' ! ,d" :",., t"-, ,''',
ROGF:íi ït tOLl-oN
BusINSS ADDRESS:Fisher Sheeha & Colton
Public Fince and Gener Ecnomics
34 Warck Road, Belmont, MA 02478
617-484-0597 (voice) *** 617-484-0594 (fax)
rogerØfsconline.com (e-mai)
htt://ww.fsconline.com(ww address)
EDUCATION:
J.D. (Order of the Coif), Univerity of Florida (1981)
M.A. (Enomics), McGrgor School, Antioch University (1993)
B.A. Iowa Sta Univerity (1975) Gouri~ politica science, speech)
PROFESSIONAL EXPERINCE:
Fisher, Sheehan and Colton, Public Finance and General Economics: 1985 - preset.
As a co-founder of ths ecnomics consti parerhip, Colton provides serces in a
varety of areas, includig: reguatory economics, povert law and ecnomics, public
benefits, fai housin, communty development, energy effciency, utiity law and
economics (energy, telecommuncations, water/sewer), governent budgeti, and plan
and zonig.
Colton has testfied in sta and feder cour in the United Stas and Ca as well as
before reguatory and legislative boes in more th thee dozen states. He is parcularly
noted for creative progr design and implementaon with tight budget consts.
National Consumer Law Center (NCLC): 1986 - 1994
As a sta attorney with NCLC, Colton worked on low-income energy and utity issues. He
pioneered cost-justicaons for low-income afordle energy rates, as well as developing
models to quatify the non-energ benefits (e.g., reuce creit and collecon costs,
reduced workig caita) of low-income energy effciency. He designed and implemented
low-income afordable rae and fuel assistce progr acoss the counti. Colton was
charged with developing new pratica and theoretical underpings for solutions to low-
income energy problems.
Colton Vitae--Page 2
Community Action Research Group (CARG): 1981 - 1985
As st attrney for ths non-profit research and consultig organtion, Colton worked
priy on energy and utiity issues. He provided legal representaon to low-income
persns on public utilty issues; provided legal and tehncal assistce to consumer and
labor organtions; and provided legal and techncal assistce to a varety of state and
local governents nationwide on natu gas, electrc, and telecommuncations issues. He
routinely appeared as an expert witness before reguatory agencies and legislative
commttees regarding energy and telecmmuncaons issues.
PROFESSIONAL AFIATIONS:
Coorditor:
Coorditor:
Member:
Chai:
Past Chai:
Past Membe:
Past Member:
Past Member:
Past Member:
Past Member:
BelmontBudge1.org (Belmont's Communty Budget Foru)
Belmont Afordble Shelter Fund (BASF)
Board of Dictors, Belmont Housing Tru Inc.
Housing Work Group, Belmont (M) Comprehensive Plang Process
Waverley Squa Fir Staon Re-use Study Commtte (Belmont MA)
Belmont (M) Energy and Facilities Work Group
Belmont (M) Uplands Advisory Commttee
Advisory Boar: Fai Housing Center of Grter Boston.
Fai Housing Commttee, Town of Belmont (M)
Aggrgation Advisory Commtt, New York State Ener Resech and
Development Autority.
Past Membe: Board of Dirors, Vemont Energy Investent Corpration.
Past Member: Board of Dirrs, Nationa Fuel Funds Network
Past Member: Nationa Advisory Commttee, U.S. Deparent of Health and Hum
Services, Admston for Children and Famlies, Performance Goals for
Low-Income Home Energy Assistce.
Past Member: Edtorial Advisory Boar Intertiona Libra, Public Utility Law
Anthology.
Past Member: ASHR Guidelines Commtt, GPC-8, Energy Cost Allocation of
Comfort HVAC Systems for Multiple Occupancy Buildings
Past Member: Nationa Advisory Commttee, U.S. Deparent of Housing and Urban
Development, Calculation of Utility Allowances for Public Housing.
Pas Member: Natonal Advisory Board: Energy Fincing Alterntives for Subsidized
Housing, New York Sta Energy Reseh and Development Authority.
PROFESSIONAL ASSOCITIONS:
National Assoiation of Housin and Redevelopment Offcials (NAHO)
Association for Enterprise Opportty (AEO)
Iowa State Bar Association
Energy Bar Assoiation
Association for Intutiona Thought (AFIT)
Association for Evolutiona Ecnomics (AEE)
Colton Vita--Page 3
Society for the Study of Social Problem (SSSO)
International Society for Policy Studies
Association for Social Ecnomics
BOOKS
Colton, et al., Access to Utiit Serice, National Consumer Law Cente: Bosn (4th edtion 2008).
Colton, et ai., Tenants'Rights to Utiit Sere, Natona Consumer Law Ceter: Bostn (1994).
Colton, The Reglin of Rural Elect CooperaJ, Natonal Consumer Law Center Boston (1992).
JOURNAL PuBLICATIONS
Colton (Novembe 2003). "Winte Weater Payments: The Impa of Iowa's Winter Utity Shutff Moratorium on
Utility Bil Payments by Low-Income Cumers." 16(9) Eleit Journal 59.
Colton (Mh 2002). "Energy Consumption and Expnditus by Low-Income Housholds,"15(3) Electit Journal
70.
Colton, Roger and Stehen Colton (Spri 2002). "An Alterve to Reguation in the Contrl of Ocuponal
Expsur to Tubulosis in Homeless Shelter," New Solutins: Journal of Envronmeta and Occupaonal Healt
Policy.
Colton (2001). "The Lawflness of Utity Actons Sekig to Impose as a Condition of Serce Liabilty for a
Roommate's Debt Incmr at a Pror Addrss, Clearghouse Review.
Colton (2001). "Limitig Th "Famy Necessaes" Doe as a Means of Impoing Th Par Liabilty for Utility
Bils," Clearighouse Rev.
Colton (2001). "Prepayment Utiity Meters and the Low-Income Consumer." Jounu of Housing an Commnit
Develpmet Law (Amerca Ba Assoiation).
Colton, Brown and Ackeran (June 200). "Merger and the Public Interest: Savig the Savigs for the Poorest
Customers." Public Uti Fol1ightly.
Colton. (2000). "Agggation and the Low-Income Consumer." LE Newsler.
Colton. (1999). "Chalengin Entrce an Trafer Fee in Mobile Home Par Lot Renta." Clerighouse Revie.
Colton and Adas (1999). "Y2K and Communities of Color," Meda Ale: The Quat1ly Publiation of the
National Black Media Coatin.
Colton and Sheeha (1999). "The Problem of Mass Evictions in Mobile Home Par Subjec to Conversion." Journal
of Housing and Colt Develpme La (Amerca Bar Assoiaion).
Colton (1999)."Utility Rae Classifications and Group Homes as "Residetil" Cumers," Clearighouse Rev.
Colton (1998). "Provider of Last Resort: Lessns frm the Inurce Indust." The Eletrcity Journa.
Colton and Ada (1998). "Fingerrits for Check Ca: Where Lies the Real Fraud," Media Aler The QuaT1erly
Publiatn of the Natna Blok Med Coatin.
Colton Vitae--Page 4
Colton. (1998). "Univer Serce: A PerormceBas Meae for a Compeitive Indust," Public Utilies
Fortightl.
Colton, Roger and Stephen Colton (1998). "Evalua Hospital Merger," 17 Hea Affai 5:260.
Colton. (1998). "Supportve Housing Faciles as "Low-Income Residential" Cumers for Energy Effciency
Puoses," 7 Journal of Housing and Commit Developmet Law 406 (Amerca Bar Assoiation).
Colton, Frisof and Kig. (1998). "Lessons for the Heath Car Indus frm Amerca's Expence with Public
Utiities." 18 Journal of Puli Heah Poli 389.
Colton (1997). "Fai Housing and Afordale Housing: Availailty, Disbution and Quity." 1997 Collqui:
Cornell Journal of Plnning and Urban Issues 9.
Colton, (1997). "Competion Comes to Electrcity: Industr Gas, Peole and the Envionment Lose," Dollars and
Sense.
Colton (1996). "The Road Oft Taken: Unaordale Home Ener Bills, Forc Mobilty And Chidhood Edcation in
Misour." 2 Journal on Chilren and Pov 23.
Colton and Sheeha. (1995). "Utity Frachise Chares and the Renta of City Prpe." 72 New Jerey
Municipalti 9:10.
Colton. (1995). "Arg Agast Utities' Clai of Fede Preemption of Cutomer-Serice Regulations." 29
Clearinghouse Revie 772.
Colton and Labella. (1995). "Ladlord Faiur to Resolve Shar Meter Prblems Breches Tent's Right to Quiet
Enjoyment." 29 Cleringhouse Revie 536.
Colton and Morrsey. (1995). "Tents' Rights to Prtetion Notice in Cas of Ladlords' Nonpayment of
Utiities". 29 Clerighouse Rev 277.
Colton. (1995). "The Pervers Incentives of Fai Market Rents." 52 Journal of Housg and Commnit
Developmet 6.
Colton (1994). "Energy Effciency and Low-Income Housing: Ener Policy Hur the Poor." XV ShelForce: The
Journal of Affordle Housing Stat 9.
Colton (1994). "The Use of Consumer Credit Rep in Esblishig Creitwortes for Utility Deposits."
Clearinghouse Rev.
Colton (1994). "Intitutiona and Regury Issues Affecg Ban Prodct Diversificaon In the Sale of Inurce,"
Journal of the Aman Socie ofCLU an ChFC.
Colton. (1993). "The Use of Stae Utity Reguatons to Contrl the 'Unrguate' Utility." 27 Clearighouse Rev
443.
Colton and Smith. (1993). "The Du of a Public Utity to Mitgate 'Dages' frm Nonpayment though the Offer of
Conservaton Prgr." 3 Boston Unierity Puli Interes La Journal 239.
Colton and Sheehan. (1993). "Cash for Cluner Prgr Can Hur the Poor," 19 Stat Leglare: Natnal
Conferece of Ste Leglatres 5:33.
Colton. (1993). "Consumer Information and Workble Competition in the Telecommunicaons Indus." XXII
Journ of Economi Issues 775.
Colton Vitae--Page 5
Colton and Sheehan. (1992). "Mobile Home Rent Contrl: Prtecg Loal Regulaton," Lad Use Law and Zoning
Digest.
Colton and Smith (1992 - 1993). "Co- Membehip and Utity Shutff: Service Proteons tht Are as an
Incident ofREC 'Membership.'" 29 Idaho Law Rev i, reprinted, XV Public Utili Law Anthology 451.
Colton and Smith. (1992). "Prtecons for the Low-Income Cusomer of Unrguated Utilies: Federa Fuel
Assistace as More th Cah Grats." 13 Ham Unierit Joumo of Publi Law and Poli 263.
Colton (1992). "CHAS: The Energy Connecon," 49 The Journal of Housing 35, reprinted, 19 Cu"en Municipal
Proble 173.
Colton (March 1991). "A Cost-Basd Respns to Low-Income Ener Problems." Publi Uti Fortightl.
Colton. (1991). "Protectg Again the Har of the Misten Utiity Underchage." 39 Washington Univerity
Journal of Urban and Contorary Law 99, repinted, XI Pubüc Uti Anthology 787.
Colton. (1990). "Cusmer Consumption Pat with an Income-Bas Energy Assisce Prgr." 24 Journal of
Economi Issue 1079
Colton (1990). "Heightening the Burden of Prf in Utilit Shutff Cas Involvig Alegatons of Fraud. " 33 Howard
L Review 137.
Colton (1990). "When the Phone Compay is not the Phone Compy: Credt Reprtg in the Pos-Divestitu Era."
24 Clearighouse Revie 98.
Colton (1990). "Discration as a Sword: Use ofan 'Effect Test' in Utity Litigation." 37 Washington Univerity
Journal of Urban and Contemrary Law 97, reprinted, XII Publi Utili Anthology 813.
Colton (1989). "States of Limtaons: Barg the Deliquent Disconnecon of Utiity Serice." 23 Clringhouse
Revew 2.
Colton & Sheehan. (1989). "Rasing Loal Revenue thug Utility Frachise Fees: When the Fee Fit, Foot It." 21
The Urban Lawyer 55, reprinted, :x Public Utili Anthology 653, reprinted, Freilch an Bushek (1995).
Exctions, Imp Fees and Dedicatons: Shaping Land Use Develpme and Fundig Infrtrcture in the
Dola Era, Amerca Bar Associaton: Chicao.
Colton (1989). "Unlwfl Utity Dinnecons as a Tort: Gag Compenson for the Hars of Unlwf
Shutoffs." 22 Clearghouse Review 609.
Colton, Sheehan & Uehlg. (1987). "Seven cum Eleven: Rollig the Toxic Dice in the U.S. Supreme Cour" 14
Boston Colle Environmeal L Rev. 345.
Colton & Sheeha. (1987). "A New Basis for Constion Prgr for the Poor: Expdi the Concept of
Avoided Costs," 21 Cleringhous Revew 135.
Colton & Fisher. (1987). "Public Inducement of Local Economic Development: Legal Consints on Goverent
Equity Funding Progr." 31 Washingtn Univerit J. of Urb and Conterary Law 45.
Colton & Sheeha (1986). "The ilinois Review of Natul Ga Prurement Prce: Persible Regution or
Federaly Prempte Actvity" 35 DePaul Law Rev 317, reprinted, IX Puli Utilit Anolog 221.
Colton (1986). "Utility Involvement in Ener Mangement: The Role of a Sta Power Plant Cerfication Statue."
16 Environmetal La 175, reprinted, IX Puli Uti Anolo 381.
Colton Vita--Page 6
Colton (1986). ''Utility Servce for Tents of Delinquent Ladlords" 20 Qearinghouse Rev 554.
Colton (1985). "Muncipa Utility Fincing of Energy Conseration: Can Loan only be Mad thugh an IOU?". 64
Nebraska Law Rev 189.
Colton (1985). "Excess Capacity: A Case Study in Ramakg Theory and Applicaon." 20 Tulsa Law Journal 402,
reprinted, VI Publi Utiites Antholo 739.
Colton (1985). "Consation, Cost-Containent and Full Energy Servce Corprations: Iowa's New Defition of
'Reasnably Adeqte Utiity Seice.'" 34 Drake Law Journ 1.
Colton (1984). "Prdence, Plag and Prcipled Raemakg." 35 Hasgs Law Journal 721.
Colton (1983). "Excess Capacity: Who Gets the Chare frm the Power Plant?" 33 Hasgs Law Journal 1133.
Colton (1983). "Old McDonad (Inc.) Has a Far. . . Maybe, or Nebraka's Corpra Far Ban Is it Constitutional?"
6 Univers of Arka at Li Rock La Revie 247.
Colton (1982). "Mandatory Utilty Fincing of Conseon and Solar Measurs." 3 Solar Law Reprter 167.
Colton (1982). "The Use of Canons of Statory Constrction: A Cas Study frm Iowa, or When Does 'GHOTI'
Spell 'Fish'?" 5 Setn Hal Legislave Journal 149.
Colton (1977). "The Cas for a Broa Constrction of 'Use' in Seion 4(t) of the Deent of Trasprton Act."
21 St Loui Law Journ 113.
OTHR PuLICATIONS
Colton (2011). Home Ener Affordabilit Gap in New York, prear for the New York Stae Energy Research
Development Authority (NSERDA) (Albay, NY.
Colton (2011). Home Ener Affordoil Gap: 2010: Connec Lelae Disct, pre for Option Fuel
(Bloomfield, Cn.
Colton (2010). Inter Report on Xcel Ener's Piot Ener Assistance Program, prear for Xcel Energy
(Dnver, CO).
Colton (2010). Home Energ Afordoil Gap: 200: Connectut Lelae Dis, pred for Opraon Fuel
(Bloomfield, CT).
Colton (2010). Home Ener Affordoilty in Manitba: A Low-Income Affordobili Prgram for Manitoba
Hydro, prpa for Resur Consation of Mantoba, Winpeg (M.
Colton (2009). Mirror, MuTor on the Wal How Wel Doe Belmnt's Town Meetg Reflct the Commnit at
Large, prepard for Fisher, Sheeha & Colton, Public Fince and Gener Economics, Belmont (M).
Colton (2009). An Outcomes Planning Approach to Sering TPU Low-Income Cusme, prared for Tacoma
Public Utilities, Tacma (W A).
Colton (2009). An Outcme Evalatn of Indi's Low-Incme Rat Afortil Program: 2008 - 2009,
prepard for Citi Gas and Coke Utility, Norter Indian Public Servce Company, Vect Energy Delivery
Indianpolis (I.
Colton Vitae--Page 7
Roger Colton (200). The Eared Inco Tax Credi (ElTe as "Ener Asce" in Pennslvana, pre for
Pennylvan Utility Law Prjec (PULP).
Colton (2009). Ener Effiecy as a Homeuyer Affordil Tool in Penlvia, pre for Pennlvana
Utility Law Projec Harburg (PA).
Colton (2009). Ener Effie Uti Allwances as a Usage Reductn Tool in Pensylv, prepaed for
Penylvania Utility Law Prjec Harburg (PA).
Colton (2009). Home Energ Consumptin Exenres by Incom (Penlvia), prear for Penylvana
Utity Law Prjec Harbur (P A).
Colton (2009). The Contrutn of Uti Bills to the Unafordail of Low-Income Renl Housing in
Pennsylvania, preard for Penylvana Utity Law Projec Harbur (P A).
Colton (2009). The Integn of Fedal LIHEA Benfi wit Ratayer-Funded Percege of Income
Payme Programs (PIPPS): Legal and Poli Questins Involvg the Disutin of Benefts, prepared for
Pensylvana Offce of Consumer Advocte, Haburg (P A).
Colton (2008). Home Ener Afordtbil in Indiaa: Cun-en Need and Future Potenti, prepared for Indiana
Communty Action Associaton.
Colton (2008). Publi Heah Outcome Asoci wit Ene Povert: An Anasis of Behavra Rik Factor
Surveillnce Syste (BRFSS) Dat from Iowa, preared for Iowa Deparent of Hum Rights.
Colton (2008). India Bilng and CoUectn Reprtg: Natra Gas and Electc Utiti: 2007, prard for
Coalition to Keep Indian War.
Colton (2008). Invert Block Tariff an Unial Lifele Rat: Their Use an Usabil in Delrig Low-
Income Electr Rat Relief, prepard for Hydro-Quebe.
Colton (2007). Bes Practes: Low-Income Affordailit Prgrams, Artlag and Applying Ratng Criteria,
prepard for Hydro-ebec.
Colton (2007). An Oucome Evaatn of Indiana's Low-Income Rat Affordail Prgrams, peormed for
Citizns Ga & Coke Uti, Vecn Ener Delivery, Norter Indi Pulic Sece Compay.
Colton (2007). A Mult-stae Stdy of Low-Income Prgram, in collabration with Apprise, Inc., prepard for
multiple stdy sponsrs.
Colton (2007). The La an Economi of Detering Hot Wat Ener Use in Calulag Utili Allwances
for Publi an Asis Housing.
Colton (2006). India BiDing and CoUectn Reportg: Natral Gas and Elec Uti: 2006, prepared for
Coaltion to Keep Indian War.
Colton (2006). Home Ener Affordtbil in Marymnd: Necessary Reglary an Leisla Actns, pred for
the Malad Offce of Peoples Counel.
Colton (2006). A Ratepayer Funded Home Ener Afordabil Prgr for Low-Income Houshold: A Unival
Service Program for Ontari's Ener Utiti, prepar for the Low-Income Energy Network (Toronto).
Colton (2006). Georg RECH Prject Energize: Final Prgram Evalatn, pre for the Georgia Depaent
of Hum Resours.
Colton Vitae-Page 8Colton (2006). Exertal Low-Incom Prgram (EUP): Empire Dis Elect Compan, Final Program
Evaluatn, prepared for Empir Distrct Electrc Compy.
Colton (2006). Munical Aggregatin for Retil Natral Gas and Ele Ser: Poten, PiaUs and Poli
Impliatns, prepa for Marland Ofce of Peoples Counl.
Colton (2005). Indiana BiUing and CoUectn Reprtg: Natral Gas and Elec Uti: 2005, prepared for
Coalition to Keep Indiana War.
Colton (2005). Imact Evalatn of NIPSCO Winter Warm Prgram, prepar for Norern Indi Public
Serice Company.
Colton (2005). A Water Affordail Prgram for the Detoit Wat and Sewer Depart, prepad for Michigan
Povert Law Center.
Colton (2004). Pai but Unaffordable: The Consequences of Ener Pove in Missouri, prear for the National
Low-Income Home Energy Consrtum.
Sheehan and Colton (200). Fair Housing Pla: An Analsis of Impents and Stat on How to Addres The:
Washington County/Beavrtn (OR), prepared for Wasington County Deparent of Communty Development.
Colton (200). ContlHng Tubercusis in Fuhn Count (GA) Hollles Shel: A Needs Assessmt, prepared
for the Georgia Depaent of Human Resoures, Division of Public Health.
Colton (2003). The Impact of Missouri Gas Energ's Exermental Low-Income Rate (ELIR) On Utility Bill
Payments by Low-Income Customers: Preliminary Asessmet, prepared for Missour Gas Energy.
Colton (2003). The Economi Deelopmet Impac of HolI Ener Asistance: The Enterg Sta, prepard for
Entegy Services, Inc.
Colton (2003). Ener Efjiecy as an Affordab Housing Tool in Colorad, pred for Colorao :Energy
Assistace Foundation.
Colton (2003). The Economi Developme Impac of HolI Energ Asistance in Colorad, Colorao Energy
Assistace Foundaon.
Colton (2003). Measuring the Ouome of Home Ener Assisance through a Home Energ Insecuri Scale,
prepared for the U.S. Depent ofHealt and Human Serces, Admistrtion for Childrn and Famlies.
Colton (2002). Low-Incoll HolI Ene Affordail in Maryland, prep for Offce of Peoples Counl.
Colton (2002). Winter Weather Paymets: The Impact of Iowa's W"mtr Uti Shutoff Moratrium On Utili
BiU Payments by Low-Income Customer, prepaed for Iowa Deparent of Human Rights.
Colton (2002). A Fragile Income: Defe"ed Payment Plans and the Ability-to-Pay of Working Poor Utilit
Customers, prepared for National Fuel Funds Network.
Colton (2002). Credit where Credit is Due: Publi Utili and the Earned Income TfI Credi for Working Poor
Utili Customers, prepared for National Fuel Funds Network.
Colton (200 i). Integrating Goverment-Funded and Ratepayer-Funded Low-Income Ener Assistance
Programs, prepar for U.S. Deparent of Heath and Human Servces (HS) and Oak Ridge National Laboratory.
Colton (2001). In Harm's Way: HolI Heatng, Fire Hazards, and Low-Incoll Households, prepared for
Nationa Fuel Funds Network.
Colton Vitae--Page 9
Colton (2001). Reducing Ener Distres: "Seeing RED" Project Evalatn (evaluation of Iowa REACH
project), prepared for Iowa Deparent of Hum Rights.
Colton (2001). Group Buying of Proptue tud Fuel Oi in New York Stat: A Feasibil Study, prepared for New
York State Communty Acton Assoiaton.
Colton (2000). Establishing Telecommicatns Lifeline Eligiil: The Use of Puli Benefl Programs tud its
Impact on LawfulImntuts, prepared for Daytn (OR) Legal Aide.
Colton (2000). Oueah Stat for Iowa's LIHEA Prgram Innovatn in Improed Taretg, prepared for
Iowa Deparent of Human Rights.
Colton (1999). Integratin of LIHEA with Ener Assisance Programs Creatd through Elect and/or Natral
Gas Restrcturig, prepar for U.S. Dearent of Health and Human Servce, Admnisttion for Children and
Familes (Nov. 1999).
Colton (1999). Fair Housing in the Suburbs: The Role of a Mered Flee Boson in The Diverifatn of the
Suburbs Report to the Federal Reser Board Concerning the Merger of BankBoston Corp. tud Fleet Fintucial
Group, preard for Belmont Fair Housing CommttelBlmont Housing Parerhip.
Colton (1999). Meaurig LIHEA's Resul: Respondg to Home Energ Unaffordail, prepa for Iowa
Deparent of Hum Resoures.
Colton (1999). Monitrig the Impact of Ele Resctrig on Low-Income Consume: The What How tud
Why of Data Collction, preped for U.S. Depaent of Health and Human Serces, Admstrtion for Children
and Famlies.
Colton (1999). Developing Consume Educatn Progr in a Restrctred Ele Industr, prepared for Centrl
Misour Counties Communty Development Corpraon.
Colton (1999). Electrc Resctrig tud the Low-Income Consume: Leglatie Impliatns for Colorado,
prepared for Colorao Gener Assembly.
Colton (1998). Low-Income Ele Rate Affordabil in Virgnia: Fundig Low-Income Asnce, prepared for
Virgina Council Ag Povert.
Colton and Alexander (1998). The Impliatns of tu Increased Federal Role in the Regulan of Eleit on
State Regulation of Consume Protecton tud Univeral Sere Prgram.
RColton and S.Colton (1998). The Occupatnal Contol of Tuberculosis in Homes Shelt, prear for the U.S.
Occupatonal Saety and Health Admtion.
Colton (1998). The Connecon Beteen Affordable Housing and Educatnal Exellence in Belmnt, preed for
Belmont Fai Housing Committee.
Colton (1998). Servng the Affordable Housing Needs of Belnt's Oldr Resid, prepar for Belmont Fai
Housing Committ.
Colton (1998). The Costs of a U1Ual Serice Fund in Minnesota: Electc and Natra Gas, prep for the
Energy Cents Coaltion.
Colton (1998). Contollng the Occunal Exsure to Tuberculsis in Homele Shelrs: Applying Federal
OSHA Stndard to Volunters, prepa for the U.S. Ocupatona Safet and Healt Admstron.
Colton Vitae--Page 10
Colton (1997). Public Housing Utiit Allowances for the Met Dade Housing Agency, prepd for Legal Serces
Corporation of Greater Mia.
Colton (1997). Low-Income Energ Needs in Maryland: An Ov, prepa for Marland Offce of Peoples
CounL.
Colton (1997). Stcturig a Public Purpse Distrutn Fee for Misouri, prepar for Misour Dearent of
Natu Resoures.
Colton (1997). The Low-Income Inte in Uti Merers and Acquisitns
Colton (1997). The Obligatn to Sere and a Restrred Elect Indu, prep for u.s. Dearent of
Energy, Oak Ridge Nationa Laoraory.
Colton (1997). Strcturig and Evauatng a Direc Vendor Payt Shadow Billing Programfor Publicly Assisted
Housing in Houston, prepard under contr to Gulf Coast Legal Foundaon (with fudig by Houston Lighting
Company).
Colton (1997). The For-Prfi Conversion of the New Englad Educatn Loan Markeg Corporatn: Lessons
from Non-Profi Hospital Converions.
Colton (1997). Ren Housing AfordaiJ in Burligtn, Vernt: A Reprt to the Burligtn Cit Council..
Colton (1997). Structrig a "Wires Chare" for New Hamshire: A Frameork for Admniatin and
Operaton, prepared under contrct to the New Hampshi Community Action Association.
Colton (1996). Setg Income Eligibilty for Fuel Asnce and Ener Effiecy Pram in a Compete
Electric Industr: The Margal Impac of Increasing Houehold Income.
Colton (1996). Fair Housing and Afordable Housing in Belnt Massahuset: Da on Avaiabili,
Distrbutin and Quality.
Colton and Sheehan (1996). Fair Housing Analsis of Impedimts Study for Washington Count (Oregon)..
Colton (1996). Strctrig a Low-Income "Wues Chare" for New Jersey, prepar for Citins Agast Rate
Escalation (CAR).
Colton (1996). Strctrig a Low-Income "Wi Charge" for Kentuky, prard for Louisville Legal Aide
Association.
Colton (1996). Stuctring a Low-Income "Wues Chare" for Iowa, pre for Iowa Buru of Human
Resources, Offce of Weation.
Colton (1996). Strcturig a Low-Income "Wues Charge" for Montana, prep for Energy Sha of Monta
Colton (1996). Stctring a Low-Income "Wires Charge" for Oklaoma, prepard for Oklahoma State Association
of Community Action Agencies.
Colton (1996). Stctrig a Low-Income "Wire Charge" for Ohio, prear for Ohio Lega servces Corpration.
Colton (199). Stctring a Low-Income "Wir Charge" for India, preard for Indian Citin Acton
Campaign.
Colton (1996). Shawmut Bank and Commit Reinvestm in Bostn: Commit Cred Needs and Affordable
Housing.
Colton Vitae--Page II
Colton (1995). Undemandig "Redlining" in a Compete Elect Uti Indu).
Colton (1995). Ener Effiecy as a Cred Enhancemt: Puli Uti an the Affordailty of First-Time
Homeownerhip.
Colton (1995). Competon in the Electc Indu: Assessing the Impct on ResidtiaL, Commcil an Low-
Income Customer, prepaed under contr to the National Association of Reguatory Utity Commssioners.
Colton (1995). Performnce-Based Evaatn of Custome CoOectns in a Comp Ele Utiit Indtr.
Colton (1995). Povert Law an Economi: Cakulg the Household Budget, preped for presentation to
National Legal Aid and Defender Assoiaton Substative Law Trag.
Colton (1995). The Needfor Reglatin in a Compet Elec Uti Industr.
Colton (1995). Rewring the Soc Compact: A Compet Elect Indu an it Core Customer.
Colton (1995). The Roa Of Tak: UlUffordale Home Ene Bills, Forc Mobil, and Chiloo Education
in Missouri, prear for the Missour Associaon of Head Sta Dictrs.
Colton (revised 1995). Mode of Low-Income Uti Rat, prard under contr to Washigtn Gas Company.
Colton (1995). Beond Soc Welare: Prmotig the Eared Income Tax Cre (EITC) as an Economic
Developmet Stat by Publi Uti.
Colton (1995). Should Reglan of Electit Depd on the Absene of Competn?
Colton (1995). Comprehenive Credi and CoUectn Stegie in a Compete Electrc Utity Industr, prepared
under contr to Hydro-Qebec.
Colton (1995). Economiall Stande Invetm in a Compete Elect Indst: A Prim for Cits,
Consume and Sn Busines Adv.
Colton (1995). Compete Solin as an Integrat Resource Plannig Model: Its Compe Impac on
Small Businesses Sering Low-Income Households, prepared under contrct to the Arka State Weatherition
Colton (1995). Reviewing Utity Low-Income DSM Prgram: A Sugges Framorkfor Anais.
Colton (1995). Least-Cost Interatd Resource Planning in Arkaas: The Role of Low-Income Energ Effiency
prepard under contr to the Ar State Weaeron Assisce Prgr.
Colton (1994). Addresing Low-Income Inabil-toPay Uti Bins During the Winter Months On Trial Lads
Sered By Elecic Co-ps: A Model Tri Wintr Uti Shutff Reglan.
Colton (1994). An Earned Income Tax Cred Uti Intn Ki .
Colton (1994). Telecommnicatns Credi and Collectins and Contolling SNET Uncollecle, preard under
contrct to the Connectcut Offce of Consumer Counel.
Colton (1994). Custome Deposit Demds by u.s. Wes Reaonable Ratnal and the Proper Assessmet of
Rik, prepar on behalf of the Staff of the Washigtn Utilies and Trarton Commsion.
Colton (1994).Credit and Collectn Fee and Low-Income Households: Ensuring Effeceness and Cost-
Effectiveness, prepa on behaf of the Missour Ofce of Public Counel.
Colton Vitae--Page 12
Colton (1994). Weatherzatin Asisance Program Evaatins: Asseing the Impac on Low-Income Abilitto-
Pay.
Colton (1994). DSM Planing in a Resti Envronmet.
Part 1: Why Ramping Down DSM Exendires Can Be "Pr" DSM
Part 2: Low-Income Oppositn to DSM: Il-Defd and Misguided
Part 3: Low-Income DSM Exenditres as a Non-Resource Acqisitn Strateg: The Potel for Niche
Markeg
Colton (1994). Lon Guaraee as a Uti Invetm in Ener E.fcy for Low-Incom Housing.
Colton and Sheehan.(1994). "Linked Desit" as a Utiit Invetm in Energ Effciecy for Low-Income
Housing.
Colton (1994). Securitzig Uti Avoided Cost: Creatg an Ener Effiecy "Product" for Prate Investmt
in WAP.
Colton and Sheehan (1994). Economi Devlopm Utity Rat: Targetng, Jushing, Enforcing, prared under
contrt to Texas ROSE.
Colton and Sheeha (1993). Afordable Housing and Sectin 8 Uti AUowances: An Evaluan and a Proposal
for Actn:
Par I: Adequac of An AUowances.
Par II: Adeuacy of Monthly AUowances.
Colton and Sheeha (1993). Idendhing Savings Ariing From Low-Income Program.
Colton (1993). Low-Income Progr And Their Impac on Reducing Uti Workig Capit AUowances.
Colton, et al. (1995). An Asses of Low-Income Ener Need in Washingtn St. Pr under contrct to
the Washigtn sta Depent of Communty Development
Colton, et al. (1993). Funding Social Serices Through Voluntary Contrutn Prgram: A Proposal for SNET
Partcipatn in Fundig INFOLINE's Informn and Referal Services in Con1Ut. Prepaed under contrct
with Unite Way of Conneccut.
Colton. (1993). Publi Uti Credit an CoUectn Actit: Establishing Stands and Applying them to Low-
Income Utiit Program. Pred under contrct to the national offce of the America Assoiation of Retied
Persons.
Colton (1992). FiUng the Gaps: Financig Low-Income Energ Asistae in Connectut. Prpad under contr
to the Connecicut St Deent of Hum Resoures.
Colton and Qui. (1992). The Impac on Low-Income People of the Increa Costfor Basic Telehone Serce: A
Study of Low-icome Masachuset Resde's Telehone Usage Paters and Their Perceptins of Telephone
Service Quality. Prar under contrct to the Massachustt Offce of the Attorney Gener.
Colton and Qu (1991). The ABC's of A"earage Forg. Prpar with a grt frm the Mar Reynolds
Babcock Foundaon.
Colton and Sable (1991). A Calforna Advate's Guid to Telephone Cusome Serice Issues. Prard with
fudi from the California Telecommuncations Educaon Trut Fund.
Colton Vita--Page 13
Colton and Levion. (1991). Ener an Pove in Nort Carolia: Combing PubUc and Pr Resources to
Solve a PuUc and Prate Proble. Prpa under contrct to the Nort Carlia Genera Assembly.
Colton. (1991). The Percenage of Income Payme Plan in Jeferson County, Kentucky: One Altrnate to
Distributing LIEAP Ben. Pr with fuds provided by the City of Louisvile, Kentucky and the Louisvile
Community Foundation.
Colton. (1991). The Ener Assurance Prgram for Ohio: A Cost-Based Resnse to Low-Income Ener
Problems. Prpad for Cincinti Legal Aid Soiet, Daytn Lega Society, and Cleveland Lega Aid Societ.
Colton. (1991). Uti-Finced Low-Income DSM: W'mningfor Everbody. Pr with fuds provided by the
Public Welfe Foundaon and the Mar Reynolds Babk Foundaon.
Colton (1991). Percenage of Income Payt Plans as an Alterate Disutin of UHEA Benef: Good
Business, Goo Govet, Good Social Poli. Prpar under contr to the New Engand Elecc System
(NES).
Colton (1991). The Forcd MobiU of Low-Income Custmers: The Indirec Impact of Shutoff on Uties and
their Custmers.
Colton (199). Controlling Uncolleti Accounts in Penlvania: A Blueprintfor Acton. Pr under contrct
to the Pennylvania Offce of Consumer Advocte.
Colton (1990). Nonparn in PubUc Benefl Pr: Lesonsfor Fuel Assisce.
Colton (1990). Why Custome Don't Pay: The Neefor Flle Colln Technique. Prd under contrct to
the Philadelphia Pulic Advocate.
Colton (1990). A Regulatory Response to Low-income Ener Needs in Colorado: A Proposal. Prared for the
Legal Aid Society of Metro Denver.
Colton (1990). Detrmg the Cost-Effecenes of Uti Cred an Colkctn Technique. Prepared with fuds
provided by the Ma Reynolds Babcock Foundation.
Colton (1990). Ener Use and the Poor: The Assocn of Consumptin with Income.
Colton (1989). Idetifying Consume Charaeriti Which are Importt to Detrming the Extece of
Workable Competn in the Interexhange Telecmmnicatns Industr. Prpard under contr to the Offce of
Public Counl of the Florida Legilatu.
Colton (1989). The Interexhange Telecommnictins Indutr: Should Regtin Depd on the Absence of
Competon. Prpa under contr to the Offce of Public Counl of the Florida Legislatu.
Colton (1989). FuelAssisnce Altatvesfor Utah. Pr under contr to the Uta State Ener Offce.
Colton (1989). Losing the Fight in Uta: High Ener Bills an Low-Income Consume. Pr under contrt
with the Uta Stae Energy Offce.
Colton (1989). The Denial of Local Telephone Seice for Nonpaymet of Toll Bil: A Revew and Assessmen of
Regulatry Litgatn (2d 00).
Colton (1988). Custme Serv Reglans for Residti Telhone Cutome in the Post-Divestire Era: A
Study of Michigan Bel Telhone Company. Prared under contrct to the Michiga Divestu Research Fund.
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EXHIBIT
n —-
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u:.a.:o:
Assessing the Cost-Effectiveness of
Low-Income Weatherization in Ida ho:
A Review of the Rocky Mountain Power Evaluation
Prepared by Roger Colton
Fisher Sheehan &Colton
Public Finance and General Economics
On behalf of the Community Action Partnership Association of Idaho
Presented to:
Idaho Public Utilities Commission
Case No.PAC-E-11-13
Presented by:
Community Action Partnership Association of Idaho
(CAPAI)
Boise,Idaho
Table of Contents
Introduction:Interest of Community Action Partnership Association of Idaho (CAPAI)1
Part 1:The Cadmus Study is an Inappropriate Basis for Decisionmaking 2
The Cadmus Study Understates Savings in Weatherized Homes 2
The Differential Impacts of the Economic Downturn and Rate Increases 3
The Higher Income is Unaccounted for in the Non-Participant Population 4
The Relative Non-Participant Savings are Likely Over-Stated 5
The Lifetime Non-Participant Savings are Overstated 7
Usage Reduction due to Shutoffs is not “Naturally Occurring”Savings 7
Failing to Account for Previously Weatherized Homes Over-states Nonparticipant Savings 9
The Inability to Explain How to Account for Federally-Weatherized Homes 9
The Failure to Account for Previously-Weatherized Homes 10
The Cadmus Study Understates the Non-Energy Benefits 11
The One-Year Reduction in Arrears Understates Improved Payments 11
Including Homes Weatherized with non-RMP Dollars in the Non-Participant Population
Inappropriately Reduces Net Arrearage Changes 12
Utility Cost Reductions Associated with Improved Arrearages were Inappropriately Excluded 13
Cadmus Inappropriately Understated the Improved Payment Patterns of Weatherization
Participants 16
The Cadmus Study Has Data Problems That Makes its Conclusions Suspect 17
The Timing of Weatherization Services and “Post-Installation”Data 17
The Treatment of Bill Credits Understates Arrearage Impacts 19
General Observations with Respect to the Cadmus Study 20
Findings and Conclusions 22
Part 2:The Necessary Components for a Cost-Effectiveness Analysis 25
General Principles of Cost-Effectiveness to Consider 25
A Special Note on Payment-Related Avoided Costs 26
The Need to Quantify and Incorporate Payment-Related Benefits 26
The Means to Quantify and Incorporate Payment-Related Benefits 27
Introduction:Interest of Community Action Partnership Association of
Idaho (CAPAI)
These comments are presented on behalf of the Community Action Partnership Association of Idaho
(CAPAI).CAPAI is a private,non-profit association dedicated to fighting the causes and conditions of
poverty in Idaho.Established in 1969,CAPAI is a membership organization with eight members that
consist of six community action partnership organizations:Community Action Partnership (CAP),
Western Idaho Community Action Partnership (WICAP), El-Ada Community Action Partnership (El-Ada),
South Central Community Action Partnership (SCCAP),SouthEastern Idaho Community Action Agency
(SEICAA),Eastern Idaho Community Action Partnership (EICAP),and two special purpose agencies,the
Community Council of Idaho (CCOI —formerly Idaho Migrant Council)and CCOA-Aging,Weatherization
and Human Services (CCOA).
CAPAI is the association of local weatherization agencies delivering the utility low-income
weatherization programs in Idaho,in addition to delivering the U.S.Department of Energy’s
Weatherization Assistance Program (WAP)services as supplemented by funding through the Low
Income Home Energy Assistance Program (LIHEAP)transfers to weatherization.
i Page
Pa The Cadmus Study is an Inappropriate Basis for Decisionmaking.
These comments provide the assessment of the Community Action Partnership of Idaho (CAPAI)of the
Cadmus study regarding the “cost-effectiveness”of the low-income weatherization program funded in
part by Rocky Mountain Power Company (Company or RMP).CAPAI finds that the Cadmus cost-
effectiveness study has serious fatal flaws throughout its analysis.These flaws make the Cadmus study
an inappropriate basis for decision-making.At the least,the flaws that CAPAI identifies should lead to
the conclusion that no basis for decision-making has been presented to the Commission.It is possible,
however,given the consistent direction of the impact of the Cadmus flaws,for the Commission to find
that had the flaws not been present,the Cadmus study would almost certainly have reported that the
Rocky Mountain Power low-income weatherization program meets standard benefit-cost tests.
rl.idy Uhf
The Cadmus study determines the net savings of the weatherized population by comparing the changes
in the participant population before and after weatherization to the changes in the non-participant
population in the same time period.Thus,for example:
>If the weatherized population reduced consumption by 18%and the non-participant population
reduced consumption by 6%during the same time period,the net reduction of the participant
population1 would be 12%(18%participant -6%non-participant =12%net).
If the weatherized population reduced consumption by 18%and the non-participant population
increased consumption by 3%,the net reduction of the participant population would be 21%
(18%participant —(-3%)non-participant =21%net).2
The phrases “weatherized population”and “participant population”are intended to be co-terminous,unless
specifically noted otherwise.
2 An increase in consumption would be a negative savings.
21 age
Several assumptions underlie the Cadmus study:
1.The first assumption in this type of analysis is that,given the fact that both the participant
population and non-participant population are subject to the same external forces in the same
time period,those external forces will operate equally on both populations.Accordingly,the
only difference that exists between the two populations will be the presence (or absence)of the
weatherization measures installed through the program.
2.A further assumption underlying this analysis is that the difference between the two
populations is constant over time.The savings for a single period is calculated and used for each
year over the course of the 25-year study period.3
Given these assumptions,the difference in consumption,therefore,is attributable to the program and
will continue over the life of the weatherization measures.We know,however,that these assumptions
are not the case in the Rocky Mountain Power situation.We know further that the participant and non
participant populations are not similar but for the presence (or absence)of weatherization.We know
finally that the differences will overstate the savings of the non-participant population and thus
understate the weatherization savings of the weatherization population.4
During the study period for the Cadmus study,the Rocky Mountain Power service territory experienced
two phenomena that would have affected the participant and non-participant populations:(1)a
substantial economic downturn;and (2)a significant increase in the price of electricity.Cadmus reports
that:
.the savings observed in the non-participant sample may be attributed to a few other
factors.
•Between 2006 and 2009 residential rates in Idaho increased by 44 percent due
to the reduction of the Bonneville Residential Exchange Credit.
•Effects of the U.S.economic recession are present in the post-installation period
of this analysis.
Cadmus refers to the savings occurring irrespective of the weatherization measures as the “naturally
occurring savings.”(Cadmus,at ES-3).
The 25-year period is the assumed life of the weatherization measures.
To the extent that the non-participant savings are over-stated,the net difference between the two populations is
understated.In the illustration above,for example,if the participant savings was 18%and the non-participant
savings was 3%(rather than 6%),the net savings would have been 15%,not 12%(18%participant —3%non
participant =15%net).
31 page
Cadmus notes that while “these factors would likely also affect the participant population...the impact
of these on their household would have been less than for the [non-]participating population.”(Cadmus,
at 18).Accordingly,one of the basic assumptions underlying the Cadmus savings estimate —that in the
absence of the weatherization measures,all external factors would operate equally on the participant
and non-participant population—is not valid for the Cadmus weatherization study.Moreover,Cadmus
acknowledges that it made no effort to adjust for the disproportionate impact that the rate increases
and economic recession would have had in generating usage reductions for the non-participant
population.(CAPAI-1-26).
Because of the disproportionate usage reduction impact of the economic recession and rate increases
on the non-participant population,the non-participant savings would be over-stated.As a result,the
net participant savings attributable to the weatherization measures would be under-stated.
The Cadmus study fails to account for the fact that its non-participant population was a higher income
population than the Weatherization population,with a corresponding greater “naturally occurring”
usage reduction that would not also be present in the participant population.The participant
population for the Rocky Mountain Power weatherization program is income-qualified at 150%of the
Federal Poverty Level.(Cadmus,at note 7,page 9).In contrast,the nonparticipant population was
identified based on their receipt of energy assistance on their Rocky Mountain Power bills.(Cadmus,at
13).The two populations,however,are not identical populations.Rather than an income-eligibility of
150%of Federal Poverty Level,the federal fuel assistance program (called the Low-Income Home Energy
Assistance Program,or LIHEAP)sets income eligibility at 60%of median income in Idaho.
Cadmus simply “assumed”that “customers receiving energy assistance were valid proxies”for the
weatherization population.(CAPAI-1-9).Cadmus deemed it to be “unduly burdensome”to determine
the number of nonparticipants in either the usage study or the payment study who would received
energy assistance,but who would not have been income-qualified to participate in the Weatherization
program.(CAPAI-1-11).
The problem with the Cadmus approach is that the external factors contributing to usage reduction
between 2007 and 2010 would not have operated on the two populations in the same fashion. Persons
in the higher “low-income”range (greater than 150%of Federal Poverty Level but at or below 60%of
median income)during this time period,for example,would have been more likely to have faced
unemployment and reductions in wage hours;they would have thus seen a more substantial reduction
in income than the population with income at or below 150%of Poverty Level.Data from the Current
Population Survey (CPS),for example,shows that between 2007 and 2010,unemployment increased by
While the Cadmus report states that the impacts would have been greater for the participating population,it
subsequently acknowledged a typographic error and the intent to state that the impact of the price increases and
economic recession on the savings for the non-participant population would have been greater than on the
participant population.(CAPAI-1-23,CAPAI-1-24).
41
150%(from 9,000 to 23,000 persons)in the population with income at or below 150%of Poverty Level.
In contrast,within the population with income between 200%and 250%of Poverty,unemployment
increased by 250%(from 2,000 to 7,000 households).The same impacts are found in the percentage of
persons who dropped out of the labor force altogether.Within the population below 150%of Poverty
Level,the number of persons who dropped out of the labor force completely increased by less than 20%
(from 212,000 to 252,000).In contrast,within the population with income between 200%and 250%of
Poverty Level,the number of persons dropping out of the labor force between 2007 and 2010 increased
by more than 30%(from 79,000 to 103,000).
The Cadmus “assumption”that the two populations were equivalent,and would react to external
factors in the same fashion absent weatherization,can be seen to be in error.Cadmus used the energy
assistance population and the weatherization population as equivalent populations when they are not.
The non-participant population used by Cadmus is,in other words,more likely to have made usage
reductions due to their loss of income.These usage reductions would be disproportionately high and
they would be temporary.As a result,the Cadmus study would over-state the “naturally occurring”
savings of the non-participant population and thus under-state the net savings attributable to
Weatherization,both immediately and in the long-term.
!ative N mt Saviiv
The process for obtaining savings for the participant and non-participant population results in a nearly
certain under-statement of the net savings attributable to the weatherization program.The Rocky
Mountain Power weatherization program treats both homes with electric heating and homes without
electric heating.Cadmus readily concedes that “not all homes completed with Rocky Mountain Power’s
funding are electrically heated.Funding for insulation measures requires a home [to]be electrically
heated[;]however funding is also available in non-electrically heated homes for other energy savings
measures...“(CAPAI-1-5).
The Cadmus comparison leading to the estimated net energy savings depends for its validity on the
assumption that the participant and non-participant groups are otherwise comparable but for the
presence (or absence)of the weatherization investments.Cadmus freely concedes that it does not
know the extent to which the presence of electric heating exists in the participant population.
According to its data request responses,“the Company is not able to provide accurate data on the
specific number of participant and non-participant homes that are heated electrically versus non-
electrically.”(CAPAI-1-6).The Company cannot separate gy of its analyses disaggregated by electric
heating and non-heating homes,including the estimation of adjusted gross savings (Table 10);the pre
and post-savings (Table 11);the payment amounts (Table 16);the reconnection summary (Table 17);or
the arrearage summary (Table 18).(CAPAI-1-7(a)—(f)).Nor can the Company separate any of its cost
benefit analyses (Tables 21,22,23)disaggregated by whether a home is electrically-heated or not.
(CAPAI-1-7(g)-(i)).
51 Page
Cadmus reports,however,that,according to the agencies delivering weatherization services using Rocky
Mountain Power funding,“between 35 and 48 percent of homes served are electrically heated,the
remainder being heated with natural gas,heating oil,or other fuels.”(Cadmus,at 3)•6
One problem with the Cadmus analysis,therefore,is that it is likely that the non-participant population
used for its analysis consisted of almost entirely electrically-heated homes.In its calculation of net
savings,the Cadmus analysis thus compares the savings in electrically-heated non-participant homes
against the savings in a melding of participant homes heating with electricity and with other fuels.
The criterion used for establishing income-eligibility for the non-participant population was whether the
household received “energy assistance”posted to the Rocky Mountain Power account.(Cadmus,at 13
[“The nonparticipant population was identified based on their receipt of energy assistance on their
Rocky Mountain Power bill...“}).Cadmus did not seek to determine whether the “energy assistance”
used to establish the non-participant population involved the receipt of LIHEAP basic cash grants,
LIHEAP “crisis”grants,or both.(CAPAI-1-10).
The problem with this approach is that,in Idaho,basic energy assistance grants are only provided for
primary heating service;crisis grants can be obtained for either primary heating or for electricity (when
not used for heating).If,therefore,the “energy assistance”used to establish income eligibility for the
nonparticipant population was a basic cash grant —this is likely since only 4%of Idaho’s total LIHEAP
allocation is used for funding crisis assistance—the non-participant population would consist only of
households using electricity as their primary heating source.7
It would be expected that gross savings accruing in a population comprised of a mix of electric and non-
electric heating homes would be substantially different from,and smaller than,the all-electric savings
found in the non-participant population.It was unfortunate,and a critical analytic mistake,for the
Cadmus study to use “energy assistance”posted to Rocky Mountain Power accounts as the surrogate
for weatherization eligibility while determining neither the mix of electric heating and non-heating
accounts in the weatherization population nor the mix of basic cash and crisis grants in the non
participant population.
6 While the response to the data request may seem to be inconsistent with this statement in the Cadmus report,it
need not necessarily be so. The weatherization agencies may know that 35%-48%of all weatherized homes heat
with electricity,without Cadmus knowing the extent to which,if at all,the specific participant homes selected for
study were amongst that electric-heating population.
The likelihood of a randomly selected household being a Crisis recipient is,in fact,even lower than 4%.While the
average LIHEAP cash benefit is $355,Crisis benefits are more than twice as high ($750).Since the Crisis benefit is
higher than the LIHEAP cash benefit,the proportion of total customers receiving Crisis will be lower than the
proportion of total dollars devoted to Crisis benefits.
6f rage
The Lifetime Non-Parti Ipant Savings are Overstated
The Cadmus study calculated a cost-benefit analysis in its study by deriving a net energy savings for the
participant population in the manner described above for a single year (1,308 kWh)and using that one-
year savings as a constant over a 25-year planning horizon.(Cadmus,at 28). The “naturally occurring
savings”in the participant and non-participant populations,in other words,are assumed to remain
constant (or at least remain constant relative to each other as between the participant and non
participant populations)over the course of the 25-year study period.
We know,however,and Cadmus acknowledges,that this is not the case.Instead,the types of savings
attributable to the economic downturn and to the price increases are not likely to persist over time.
Cadmus was asked that:“assuming usage decreases occurred due to the impact of the 44%rate increase
and economic recession,please compare the persistence of those usage reductions to the persistence of
the savings generated by the weatherization measures installed through the program.”Cadmus replied:
“It is generally assumed that behavioral changes (such as turning off lights that are not in use)are not as
persistent as physical changes (such as adding insulation or replacing an incandescent bulb with a
compact fluorescent light).”(CAPAI-1-27).
Given that the savings in the non-participant population were likely to degrade (i.e.,fail to “persist”for
as long as the “physical changes”installed by the weatherization program),compounded by the
disproportionate impact that the recession and price hikes had on non-participants,it was error for
Cadmus to use the first year non-participant savings as the basis upon which to calculate the expected
lifetime net savings attributable to the weatherization measures.The net difference in savings between
the participant and non-participant populations would grow over time as the non-participant savings
degraded.Using the first year savings would,however,take the non-participant savings at their highest
point and impute those artificially high savings over the full 25 years of the study period.
Cadmus acknowledges that it made no effort to quantify and account for the lack of persistence in the
savings in the non-participant population in its savings analysis,its payment analysis,or its cost-benefit
analysis.(CAPAI-1-28).As a result,the lifetime net savings attributable to the weatherization program
are understated.8
One of the primary assumptions underlying the Cadmus cost-benefit study is that the participant and
non-participant populations are comparable,but for the delivery of weatherization services to the
participant population.This assumption leads Cadmus to attribute certain usage reductions in the non
participant population to “naturally occurring savings”that inappropriately reduce the “net savings”
attributable to the weatherization measures.Calling it a “quasi-experimental”research design,Cadmus
explains that its:
8 This problem,too,would affect all calculations of changes in arrearages and/or payments.
7 I a g
•..approach consists of comparing the changes in pre- and post-energy consumption
between participants and a comparison group of customers who,though eligible,did
not participate in the program.By accounting for non-program-related factors that can
affect energy use from the pre-to the post-program periods, this method can provide
estimates of the ‘net’program impacts.
(Cadmus,at 16).Problems arise when the analysis does not appropriately account for program-related
factors that can affect energy use from the pre-to the post-installation periods. Under the
circumstances of the Rocky Mountain Power study,this failure leads Cadmus to over-state the “savings”
of the non-participant population and,as a result, to under-state the net savings of the weatherization
program.
Cadmus treats the participant and non-participant populations as though they were the same even
though the two populations had distinctly different shutoff characteristics.Cadmus reports that
participants had 26%fewer reconnections and 13%fewer number of sites with one or more
reconnections than did the non-participant population.It is the converse which is more important,
however.Non-participants had 26%more disconnections and 13%more sites with a disconnection than
did the participant population.This difference in the two populations would,of course,affect the usage
characteristics of the two populations.
Cadmus,however,does not account for the higher number of disconnects in its usage analysis.Cadmus
reports that virtually all disconnected accounts were both in the payment and consumption analysis.
“Only 3%of all accounts with disconnects were associated with sites that had fewer than 11 months of
billing or less than 330 billing days,and may have been dropped.”(CAPAI-1-43).
The disconnection of service does not,for the most part,affect the number of billing days by a
customer.Anyone who is disconnected and remains off the system for five or fewer days is considered
to be a continuous active customer.(CAPAI-1-17).If someone is disconnected on June 10 and
reconnected on or before June 15 that customer is deemed to have been on the system for all billing
days within the month.(CAPAI-1-17).
Days on which service is disconnected,of course,generate no consumption for the disconnected
customer.This reduced consumption,however,was not accounted for by Cadmus.Instead,the
reduced consumption caused by the 26%net higher rate of disconnections for nonpayment contributes
to a higher rate of “savings”by the nonparticipant population.Since the “natural savings” of the non
participant population is higher,the net savings for the weatherization population is reduced.
Strangely,under the Cadmus analysis,to the extent that the low-income weatherization program
succeeds in reducing the number of service disconnections in the weatherized population relative to the
non-weatherized population,the net usage reduction attributable to the program will also be reduced
8 ‘a g
and the program will be more likely to be found non-cost-effective.This occurs because the increased
number of days off the system within the nonparticipant population due to the relative increase in
shutoffs shows up as “usage reduction,”thus reducing the net usage reduction attributable to the
weatherization.
The selection of homes to be included in the non-participant population was inadequate to determine
the net impacts of weatherization on low-income housing units.To begin this section,it is important to
again summarize the assumptions that underlie the analysis performed by Cadmus.Cadmus selected a
“participant”group and a “non-participant”group.The pre-and post-installation period consumption
of the two groups were compared.The difference in usage reduction (if any)is the net reduction
attributable to the installation of weatherization measures.
flfllCS
In its study for Rocky Mountain Power,Cadmus concedes that it made an initial error in its calculation of
the net savings attributable to weatherization measures.Cadmus reports that some homes in the non
participant sample had been weatherized outside the program using non-Rocky Mountain Power
funding.(Cadmus,at 17).As a result,some portion of the non-participant savings should have been
attributable not to “naturally occurring”usage reduction,but rather to non-utility funded
weatherization services. Cadmus found that 13%of the non-participant homes had been weatherized
using such non-Rocky Mountain funds.(Cadmus,at 17 —18).
The same would be true,of course,for the payment and arrears analysis. Some portion of the reduction
in arrears and increase in payments in the non-participant population would have been attributable to
the previous receipt of weatherization services before the program periods.
Upon discovering that it had included homes in the non-participant population that had been
weatherized solely with federal funds,i.e.,with non-Rocky Mountain Power dollars,Cadmus reported
that “we adjusted the nonparticipant savings estimate to account for these homes.”According to
Cadmus,“nonparticipant annual post-usage [was]adjusted upward to account for weatherized homes.”
(Cadmus,at 18).Cadmus,however,could provide no explanation of what they did or how they made
these adjustments.Indeed,when asked to “provide a detailed explanation of how the ‘non-participant
savings estimate’was ‘adjusted’to account for homes previously weatherized solely with federal
dollars,”as well as to “provide a detailed explanation of how the ‘non-participant usage’was ‘adjusted
upward to account for weatherized homes,”9 Rocky Mountain Power objected to the request,saying
“Rocky Mountain Power and its consultants have not performed the requested analysis,and to do so
language of the data request quoted the language of the Cadmus report,page 18,including the footnote to
Table 11 on page 18.
9J
would be cost prohibitive.”(CAPAI-1-22).No adjustment was reported as being made in the payment or
arrearage analysis either.
The Failure to Account for Previouslv-Weatherized Homes
The Cadmus study erred in a second significant way in its usage and payment analysis in its treatment of
previously-weatherized homes.While it could not explain how it made the adjustment,and Rocky
Mountain Power later disclaimed such an adjustment,Cadmus noted that it had included homes that
had been weatherized using federal funding in its non-participant population.(Cadmus,at 17 —18).
Indeed,13%of the homes that it included in the non-participant population were homes that had been
weatherized using only federal monies.
The only homes that Cadmus identified as having been weatherized with non-Rocky Mountain Power
funds,however,were homes that had been weatherized during the three-year study period.When
asked to provide a distribution of the years in which those 13%of homes had been weatherized using
only federal dollars,Cadmus indicated that 84 homes had been weatherized in 2007;84 had been
weatherized in 2008;and 144 had been weatherized in 2009.(CAPAI-1-21).No homes weatherized
with federal dollars pjjpj:to 2007,in other words,were excluded from the non-participant population.
The Cadmus report states that only two criteria were used to identify the nonparticipant population:(1)
that they received energy assistance on their Rocky Mountain Power bill;and (2)that they did not
receive weatherization with Rocky Mountain Power funds during the program period.(emphasis
added)’°
Including homes weatherized with federal funds before 2007 in the non-participant population will
increase the savings observed in the study period and thus decrease the net savings attributable to the
weatherization program.The installation of weatherization measures in a home will better equip a
home to save energy over the long-term.Air infiltration controls are installed and air sealing performed.
Attic,ceiling and wall insulation is installed.Windows and doors are replaced.The result of the
weatherization process is not only an immediate reduction in energy consumption,but an improvement
in the ability of the resident to control his or her energy consumption over the long term.The ability to
engage in “naturally occurring”usage reduction,whether in response to weather,to price increases,or
to economic recession,is enhanced through weatherization.The usage in a weatherized home will be
lower,and,therefore,if weatherized homes are included in the nonparticipant population,the
difference in savings between the participant population and the “non-participant”population will be
lesser,thus seemingly indicating a reduced usage reduction impact in the newly weatherized homes.
The principle underlying a comparison of a participant population and a non-participant population is
that the comparison is of two groups who,but for the new weatherization measures provided through
‘°“The nonparticipant population was identified based on their receipt of energy assistance on their Rocky
Mountain Power bill and homes that did not receive weatherization with Rocky Mountain Power funds during the
program period.”(Cadmus,at 13).Subsequently,the non-participant population was further narrowed based on
consumption and billing data.(Cadmus,at 23 [“Participant and nonparticipant sites were removed from analysis if
any of the following screens applied...“];see also,CAPAI-1-29,CAPAI-1-31).
10 P a g
the program,are otherwise similar.For this principle to be accurately applied,the “pre-”comparison
must be between two populations of otherwise un-weatherized homes,while the “post”comparison
must be between the newly weatherized homes and the continuing un-weatherized homes.The
Cadmus Rocky Mountain Power study failed to abide by this basic evaluation design.”
The calculation of non-energy benefits associated with the improvement of payment patterns
attributable to reduced bills generated by low-income weatherization is a critical step toward
determining the “cost-effectiveness”of that weatherization program.The reduction in utility costs
associated with a reduction in nonpayment’2 affects each of the following cost-effectiveness tests:(1)
Total Resource Cost (TRC);(2)Utility Cost Test (UCT);(3)Ratepayer Impact test (RIM);and (4)Participant
Cost Test (PCT).The Cadmus study fails to adequately,or appropriately,account for the improvement in
low-income payment amounts and patterns in its cost-effectiveness study.
Cadmus calculates that the Rocky Mountain Power weatherization program results in a first-year net
reduction in arrearages of 31%.(Cadmus,at 26).Given a pre-installation period participant arrearage of
$104,this 31%improvement yields an arrearage improvement of $31.(Cadmus,note 14,page 26).
The Cadmus study incorporates this reduction in arrears into the cost-benefit by multiplying the number
of participants times the net difference in average consumer arrearages (266 x $31.32 =$8,331).(CAPAI
1-47).Clearly,the Cadmus study incorporates only the first year change in arrearage amounts in the
cost-benefit study.Cadmus concedes quite explicitly that “we have assumed that the arrearage benefit
occurs only in the first year after a home is weatherized.”(CAPAI-1-45(B)).While usage reductions are
assumed to continue over the 25 years of a measure life,the use of the 25-year measure life is not
applied to changes in payment behavior.(CAPAI-1-45(B)).The Cadmus study implicitly incorporates the
assumption,in other words,that the weatherization will improve arrearages for the first year, but that
in the second year and beyond,the payment levels of participants and non-participants will revert to
being identical.
Changes in arrearages attributable to weatherization,however,do not occur over a one-year period and
then stop.The arrearage reduction measured by the payment analysis is not simply afit year
reduction,it is an annual reduction.If the first year reduction is $31,in other words,the second year
“Cadmus has previously recognized the validity of this principle.In the low-income weatherization evaluation it
provided in response to discovery, Cadmus (then quantec Ilc)stated:“non-participants who had received
weatherization services in previous Program periods were removed from [the]non-participant sample.”(CAPAI-1-
2,Attachment)(Final Report:Washington Low-Income Weatherization Program,at note 4,page 28,prepared for
Pacific Power (January 2007).
12 “Nonpayment”includes a variety of subsets. Nonpayment should include not only complete nonpayment,but
late payments as well.Two customers with identical annual bills of $1,200,who both make annual payments of
$1,200,present substantially different cost profiles if one makes two payments of $600 in Month 6 and Month 12
and the other makes twelve equal monthly payments of $100 each.
11
arrearage reduction will be an additional $31;the third year reduction would be an additional $31.If
the change in arrearages represents an actual reduction in arrears,the reductions will continue until the
pre-existing arrearages in the participant population are eliminated (somewhat over three years for the
Cadmus study,given a pre-existing arrearage of $104).If the change in arrearages represents a reduced
growth in arrears,the reduced growth should continue until the customers are removed from the
system.In either case,to include only the first year of arrearage reduction in the calculation of benefits
inappropriately incorporates the assumption that weatherization will have an arrearage reduction
impact in that first year,but that the improved payments will not continue over time.
Including homes that have been previously weatherized in the “non-participant”population will
artificially,and inappropriately,reduce the net payment impacts calculated for the weatherization
program.As established above,while Cadmus adjusted its usage analysis (in some unspecified way)’3 to
account for homes that were weatherized exclusively with federal funds (i.e.,not using Rocky Mountain
Power funding),it did not indicate that it made a similar adjustment in its arrearage analysis.Given that
13%of the non-participant population had been weatherized during the study period using non-Rocky
Mountain Power funding,the arrearage levels of the non-participant population would reflect the
impacts of weatherization-induced arrearage improvements,even if not induced by RMP funding.
In addition,as documented above,the homes that were weatherized with non-RMP funding that were
included in the Cadmus usage “adjustment”included only homes that were weatherized with federal
funds during the study period.(CAPAI-1-21).Homes that had been weatherized exclusively with federal
funds prior to 2007 were almost certainly included in the non-participant population.’4 The arrearage
reduction benefits flowing from weatherization,in other words,were not isolated in the participant
population,but were also present in the non-participant population that had been weatherized with
federal-only funds.These arrearage reduction benefits would have flowed from federally-funded
weatherization occurring in the study period and before.To this extent,the arrearage reduction
benefits arising in the RMP participant population are substantially under-stated.
13 When asked to explain what adjustment was made,and how it was made,Rocky Mountain Power objected to the request.
Indeed,when asked to “provide a detailed explanation of how the ‘non-participant savings estimate’was ‘adjusted’to account
for homes previously weatherized solely with federal dollars,”as well as to “provide a detailed explanation of how the ‘non
participant usage’was ‘adjusted upward to account for weatherized homes,”Rocky Mountain Power objected to the request,
saying “Rocky Mountain Power and its consultants have not performed the requested analysis,and to do so would be cost
prohibitive.”(CAPAI-1-22).
14 If 13%of the non-participant population had been weatherized with federal-only funds simply in the previous
three years,it is not only “likely”,but almost a certainty that a substantial additional proportion of the non
participant homes had been weatherized exclusively with federal funds in the previous ten or fifteen years.
12 I P a g e
While the Cadmus study documented that the RMP weatherization program generated substantial
reductions in credit and collection activities,the study inappropriately excluded the cost savings
associated with those reductions from the calculation of benefits.There is no question but that the
RMP weatherization program resulted in a reduction in credit and collection activities directed toward
the participant population.Cadmus reported,for example,a 26%reduction in the number of
“reconnections”5 and a 13%reduction in the number of customers experiencing a disconnection for
nonpayment.(Cadmus,at Table 17,page 25).16 Moreover,weatherized customers made nearly 15%
more payments than did non-participants (Cadmus,at Table 15,page 24),in addition to making a higher
annual dollar payment.(Cadmus,at Table 16,page 24).
Despite these improved collections outcomes,Cadmus included no dollarized benefits in its cost-benefit
analysis.In its report,for example,Cadmus included no dollarized benefits from the increased number
of payments attributable to the receipt of weatherization.(CAPAI-1-33, CAPAI-1-35).Cadmus did not
include any:
•Avoided credit and collection costs;
•Avoid lost sales;
•Avoided bad debt;
•Avoided working capital;or
•Added revenue (arising from the redeployment of collection resources away from participants
who were now paying their bills to non-participants who were not).
(CAPAI-1-36).Neither did Cadmus include any financial benefits generated by the reduced number of
disconnections for nonpayment.Cadmus concedes that it did not incorporate any of the reduced
number of disconnections into the cost-benefit analysis.(CAPAI-1-37).Reducing the number of
disconnections through weatherization, under the Cadmus analysis,generated:
•No reduction in credit and collection costs;
•No reduction in lost sales;
•No reduction in bad debt;or
•No reduction in working capital.
(CAPAI-1-38).In addition,according to the Cadmus analysis,the reduction in the number of
disconnections for nonpayment did not result in the Company being able to redeploy its credit and
collection resources previously devoted to those service disconnections to other accounts in arrears that
Cadmus placed in a parenthetical “disconnections”after it used the term “reconnections.It did not explain how
or why the number of reconnections was an adequate or appropriate substitute for disconnections for
nonpayment.
16 Some customers,in other words,were disconnected more than one time.
13 I
had not been previously subject to collection activities (thus generating additional revenue).(Cadmus-1-
38).
There can be little question but that the avoided costs identified above are subject to quantification.
These quantified avoided costs can have a substantial impact on a benefit-cost analysis.Cadmus
conceded,for example,that low-income weatherization generates “ratepayer benefits”that it
“considered”in the Rocky Mountain Power evaluation, albeit not in a quantified manner.(CAPAI-1-4(a),
(c),(e)).’7 The Table below shows the ratepayer benefits that Cadmus claims it “considered”even
though while not “quantifying”them.
Consideration of Non-energy Benefits (CAPAI-1-4)
.considered in Quantified by Quantified by ORNLNon-ener’Benefits cadmus Study?cadmus Study?Study?
Ratepayer Benefits
Payment-related benefits
Avoided rate subsidies Yes No Yes
Eower bad debt write-off Yes No Yes
Reduced carrying costs on arrears Yes No Yes
Fewer notices and customer calls Yes No Yes
Fewer shutoffs and reconnections for delinquency Yes No Yes
Reduced collection costs Yes No No
17 Cadmus did not explain how it incorporated these benefits into its “considerations.”For example,when asked
whether,and if so how,it used the numbers from Table 16 (“payment amounts summary”)in the cost-benefit
analysis, Cadmus responded:“Table 16 reports payment behavior.The numbers from Table 16 were not directly
used in the cost-benefit analysis.”(CAPAI-1-33).When asked to provide a detailed explanation of how the results
in Table 16 were incorporated into the cost-benefit analysis,Cadmus responded:“The numbers from Table 16
were not used in the cost-benefit analysis.”(CAPAI-1-35).When asked to provide a detailed explanation of how
avoided credit and collection costs,avoided lost sales,avoided bad debt,and avoided working capital “were
incorporated into the cost-benefit analysis,”Cadmus responded:“None of these were included in the cost-benefit
analysis.”(CAPAI-1-36).When asked to provide a detailed explanation of how the results in Table 17
(“reconnection summary”)were incorporated into the cost-benefit analysis,Cadmus responded that “the numbers
from Table 17 were not used in the cost-benefit analysis.”(CAPAI-1-37).When asked to provide a detailed
explanation of how the avoided credit and collection costs,avoided lost sales,avoided bad debt,and avoided
working capital associated with the reduced number of disconnections were incorporated into the cost-benefit
analysis, Cadmus responded that “the numbers from Table 17 were not used in the cost-benefit analysis.”(CAPAI
1-38).
14 I P a g e
If one were to have taken the Net Present Value benefits of “payment-related benefits”quantified by
Oak Ridge National Laboratory (ORNL),’8 even at 2001 dollar levels,19 and applied them the same way in
which Cadmus did for the decreased arrears ($s of benefit per participant x #of participants =total $s of
benefits)(CAPAI-1-47),these payment-related benefits would have added more than $42,000 in
additional dollars of benefits arising from the RMP weatherization program.
$/part Parts Total$s
Payment-related benefits
Avoided rate subsidies /a!$0 266 $0
Lower bad debt write-off $89 266 $23,674
Reduced carrying costs on arrears $57 266 $15,162
Fewer notices and customer calls $6 266 $1,596
Fewer shutoffs and reconnections for delinquency $8 266 $2,128
Reduced collection costs $0 266 $0
Total $42,560
NOTES:
/a!No rate discount exists in Idaho and thus do reductions in discount were calculated.
These benefits alone would have been sufficient,even at 2001 dollar levels,to have moved the benefit-
cost ratios close to 1.0 in the Cadmus study,even without making any of the other corrections and
adjustments identified in these comments.(Cadmus,at Tables 21,22,23).
Moreover,even these benefits, however,do not identify the full range of benefits of the low-income
weatherization program.They do not identify the extended credit and collection benefits of
weatherization.Cadmus found, for example,that the RMP low-income weatherization program
resulted in 26%fewer disconnections for nonpayment.The staff that would have been devoted to these
disconnections,however,would not be “laid off.”Instead,these staff would be redeployed to address
the payment-troubles of non-participants who,in the absence of the program,would otherwise have
been untreated.These redeployed collection activities would have,in turn,generated an additional set
of avoided payment-related savings, including avoided bad debt and avoided working capital.The
benefit-cost ratios identified above would be improved even further through this entire set of benefits
that has been excluded from the Cadmus analysis.
In short,Cadmus inappropriately failed to include any dollarized benefits in the cost-benefit analysis to
reflect improved collection outcomes.The increased numbers of payments,the increased dollars of
payments,and the reduced number of shutoffs generated no benefits that were dollarized,quantified
and included in the cost-benefit analysis.
18 Martin Schweitzer and Bruce Tonn (April 2002).Nonenergy Benefits from the Weatherization Assistance
Program:A Summary ofFindings from the Recent Literature,Oak Ridge National Laboratory:Oak Ridge (TN)
(hereafter,“Oak Ridge”).
19The Oak Ridge study was released in 2002.It used 2001 dollar levels.
15 I ‘a g e
v Understated
The Cadmus analysis of weatherization participants and non-participants documented that the
weatherization program generated substantial improvements in the payment patterns amongst the
weatherization participant population.According to the Cadmus study,weatherization participants
made nearly 15%more payments as a result of the weatherization program.The net increase in
customer-provided payments reached $244 for weatherization participants.(Cadmus,at 24).
Cadmus errs by not adjusting the “total bill”to eliminate miscellaneous charges such as late payment
charges, disconnection and reconnection charges,returned check charges,field collection charges,and
the like in examining these changes in payments.Rocky Mountain Power imposes a variety of
“regulatory charges”(Schedule 300,RMP Residential Tariffs).It imposes a monthly 1%late payment
charge (Schedule 300,Sheet SR.1);a $20 charge for returned checks (Schedule 300,Sheet 8R.2);and a
“reconnection charge”of either $25 or $50 (depending on whether the reconnection occurs during
regular business hours or not).(Schedule 300,Sheet 1OR.6).The Company imposes a $20 “field service
collection charge.” (Schedule 300,Sheet 1OR.8).
The fact that nonparticipants would have a disproportionate relative increase in their bills devoted to
such fees necessarily follows from the study findings regarding payments and arrearages.A reduced
level of arrearages attributable to weatherization would necessarily imply a reduced portion of the bill
caused by late payment charges.The reduced number of reconnections necessarily implies a reduced
amount of the total bill attributable to field collection charges and to reconnection charges.
The fact that weatherization participants increased their payments by $244 relative to non-participants
does not capture the full beneficial impact of the weatherization program.The true benefit of the
weatherization program is the amount by which the program participants increased their payments
toward their bill for current usage,not merely toward their total current bill.It is as important,if not
more so,that the weatherization program enabled the program participants to reduce the payments
being siphoned off to pay the miscellaneous customer service fees.Note,for example,that RMP’s
weatherization participant population increased their payments by $231 from the pre-to post-
installation period,while the non-participant population decreased their payment by $13.(Cadmus,at
24).This result is significant because not only did the non-participant population reduce its payments,
but a higher proportion of the payments that this population did make was applied to charges other
than bills for current consumption.The reduction in payments applied to their bill for current usage
would be even greater than their gross reduction impacts.
Cadmus made no effort to determine the make-up of the bills that were being paid by participants and
by non-participants.When asked for a disaggregation of bills by the type of charge,including how much
represented bills for current consumption (e.g.,customer charge,usage charge,riders)and how much
represented late payment charges and customer service fees,Rocky Mountain Power objected,saying
that Cadmus had not performed such an analysis and to do so would be cost-prohibitive.(CAPAI-1-34).
The payment objective of weatherization is not simply to increase the payment of total bills,but to
16 I P a e
increase the payments made toward bills for current usage.The Cadmus cost-benefit study did not even
seek to determine or document these benefits of increasing payments toward bills for current usage.2°
Aside from the fundamental methodological issues identified above,which demonstrate that Cadmus
systematically understated the benefits of RMP’s low-income weatherization program,the Cadmus
study exhibits other data problems that throw the validity of the study into doubt.
Cadmus reports that its analysis is based on a comparison of 12 months of “pre-installation”data and
12-months of “post-installation”data.According to the Cadmus report,for its usage analysis,the “pre
installation”period was defined to be the calendar year 2006 and the “post-installation”period was
defined to be the 12 months ending September 2010 (i.e.,October 2009 through September 2010).
(Cadmus,at 16).The payment analysis was similar.According to Cadmus,“Rocky Mountain Power
provided monthly payment data for the low-income customer sample from January 2006 to October
2010.”(Cadmus,at 22).For the payment analysis,Cadmus defined the “pre-installation”period as
calendar year 2006 and the “post-installation”period as the 12 months ending October 2010 (i.e.,
November 2009 through October 2010).(Cadmus,at 23).
What Cadmus does not do is to explain the discrepancy between how it defines the “post-installation”
period and the data it has available identifying the dates on which weatherization was actually
performed.Remember that:
>In the usage analysis,three months out of 2009 were included in the “post-installation”period
(October,November, December);
In the payment analysis,two months out of 2009 were included in the “post-installation”period
(November, December).
Cadmus reports that it originally identified 266 weatherized homes to use in its analysis.(Cadmus,at
14).Of the 266 participants,113 were weatherized sometime during 2009.(Cadmus,at 14).There were
more weatherized homes from 2009 than for either of the other two years (2007: 64 weatherized
homes;2008:89 weatherized homes).Cadmus could not provide the same breakdown for its payment
analysis.When asked “of the 229 participants used in the payment analysis,please indicate the number
of participants on which weatherization was completed in 2009,”the Company responded that neither
20 To fail to account for this would generate the impact that improving payment patterns would result in decreased
payments by weatherization participants since bills would no longer include a component directed toward late
payment charges,customer service fees and the like.Under this approach,the more successful the weatherization
program would be in improving payment patterns,the less likely the program would be found cost-effective.The
overall level of payments of program participants would decline relative to non-participants who face constant or
increasing customer service fees.
17 I
it nor Cadmus had done that analysis and to do so would be “unduly burdensome”and “cost
prohibitive.”(CAPAI-1-14(c))
Somewhat fewer participants were identified for the payment analysis,however,than for the usage
analysis.(Cadmus,at 23).Cadmus does not know,however,and could not produce,the number of
overlaps between the 229 accounts used in the payment analysis and the 166 accounts used in the
consumption analysis.(CAPAI-1-29;see also,CAPAI-1-31(a)).2’
Cadmus reports that due to the fact that the only “date”it could obtain on program participants was
“the date Rocky Mountain Power entered the program data into its system,”it was “difficult to
determine the specific program year in which jobs were completed.”(Cadmus,at 14).Cadmus stated
further that”...we were unable to identify the date weatherization was completed and therefore
unable to specifically determine start and end dates for the pre- and post-installation periods for the
billing analysis.”(Cadmus,at 14).
Nonetheless,the available evidence indicates that the weatherized units occurring in 2009 were
completed later in the year rather than earlier in the year.Cadmus reports,for example,that the
quality of weatherization delivered by the local agencies improved after those agencies changed their
policies “during the summer of 2009”to ensure that post-weatherization inspections were performed
by persons other than the persons installing the weatherization in the first instance.(Cadmus,at 9)
Some substantial number of weatherized units,in other words,were treated the “summer of
2009” for this policy to have had an impact.
The use of 2009 weatherized units is problematic from the perspective of the Cadmus usage and
payment analyses.Cadmus was asked to distribute the number of homes weatherized in 2009 by the
month in which the weatherization was completed.Cadmus could not provide the month in which 2009
weatherization was completed for either the participants used in the consumption analysis (CAPAI-1-
14(a)—(b))or for the participants used in the payment analysis ((CAPAI-1-14(c)—(d)).
Given the above information,that:
1.units weatherized in 2009 were completed after the summer of 2009;and
2.that the “post-installation”usage and payment analysis used data from October,November and
December 2009;and
3.that Cadmus is not able to report the months in which units weatherized in 2009 were treated,
21 Remember,the 229 participants identified for the payment analysis were those identified before applying the
further screens.The 229 participants identified for the payment analysis are comparable to the 266 identified for
the consumption analysis,not to the 166 finally used in the usage analysis.Cadmus did not identify the number of
participants ultimately used in the payment analysis (i.e.,the payment analysis equivalent to the 166 usage
analysis population).
18 I a g e
it is not even possible to confirm that either the usage or the payment data used in the “post
installation” period was,in fact,comiIeteIy within the p-installation period.22 Any participants
weatherized in September 2009 or later would not provide a full twelve months of post-installation
billing data.Any units weatherized in October 2009 or later would not provide a full twelve months of
post-installation consumption data.The post-installation data for participants from 2009 appears likely
to have included a mixture of both pre- and post-installation data.
The impact of this data problem will be to understate the benefits of the RMP weatherization program.
To the extent that Cadmus included “pre-installation”months in the “post-installation”period for
program participants,the calculated consumption will be higher than it would be had those months
included the reduced consumption generated by the weatherization.Moreover,to the extent that
Cadmus included untreated months in the “post-installation”period for program participants,the
payments made by those program participants would be directed,in part,toward usage (and thus bills)
that would not have been reduced;including only post-installation payments and bills would have
resulted in an even greater reduction in arrears.
Credits Understates Arrearage Impacts
Cadmus reports that it bases its analysis of arrears on the “ending balance amount across the 12-month
period.”(Cadmus,at 26).In doing this calculation,however,Cadmus made a critical methodological
error.When asked how monthly credit balances were treated in the examination of the “ending balance
amount,”Cadmus responded that “no adjustments were made;the data was used as provided.Credit
balances were combined with debit balances to produce the totals over the study period.”(CAPAI-1-44).
The effect of this approach,of course,is to take the credit balance of Customer A to reduce the
arrearage balance of Customer B,an impact that does not occur in fact.The Cadmus approach does not
even make sense from a conceptual perspective.The question would be:how many dollars in arrears
are the participant and non-participant customers?In response to that question,customers do not run
“negative arrears.”If a customer has a credit balance on his or her bill,the answer to the question is
“$0.”If a customer has a credit balance of $50,the customer has $0 in arrears (not a -$50 in arrears).It
certainly would be inappropriate to take that credit balance and reduce the arrears of a different
customer as a result.Under the Cadmus approach,a customer with a bill credit of $50 when matched
with a customer with an arrears of $50 would generate the conclusion that the average arrears was $0.
The impact is not small.Cadmus provided the “low-income billing history”in response to discovery in
this proceeding.(CAPAI-1-34).Since Cadmus provided no explanation of,or data dictionary for,this
“billing history,”the billing history for the most part was less-than-helpful.Nonetheless,it is still
possible to determine that the impact of this mis-specification of how to calculate “average arrears”is
22 Remember that bills would be issued one month after the fact.Bills rendered in October,for example,would
reflect September consumption in whole or part (along with the corresponding billed revenue).
19 I P a e
substantial.Taking the “balance forward”as the statement of arrearage levels,of the 32,761 records
provided for 2010:23
9,667 billing months (30%)had a “balance forward”of greater than $0 (i.e.,had an “arrears”);
>8,236 billing months (25%)had a “balance forward”of less than $0 (i.e.,had a bill credit);and
14,858 billing months (45%)had a “balance forward” equal to $0 (i.e.,were paid in full without a
bill credit).
As can be seen,to use the “bill credits”to reduce the arrears of accounts having arrears would
substantially understate the arrears over the course of the study period (January through early
November,2010 in the example above).Because of this methodological flaw in its calculation of
“average arrears,”the Cadmus study provides no useful information about the impact of the
weatherization program on arrears.
The Cadmus study can be found to be supportive of the cost-effectiveness of low-income weatherization
as much as to find that low-income weatherization is not cost-effective.According to Cadmus,the
usage reduction found by its billing analysis was bounded by a 26%precision band at the 90%
confidence level.(Cadmus,at 17).Cadmus also applied the 26%precision band to its arrearage analysis.
(CAPAI-1-20). This precision level indicates that any number within the confidence band is as likely to be
accurate (and not occurring at random)as any other number.
Cadmus provided a restatement of its cost-benefit calculations using the upper bound of the confidence
band rather than the mid-point for its consumption analysis.Using the upper bound solely for the usage
reduction calculation yields the following restated Table 21 (cost-effectiveness without non-energy
benefits)and Table 23 (cost-effectiveness with non-energy benefits).
The Restated Table 21 inserts the upper range of savings into the calculation of benefits excluding non-
energy benefits.
Restated Table 21 Using Upper Bound of Savings Estimate (1,648 kWh):Program Cost-Effectiveness
Summary for 2007—2009 (CA°Al-1-19)
Levelized $/Benefit!CostCost-Effectiveness Test Costs Benefits Net Benefitskwh Ratio
Total Resource +Conservation added (PTRC)$0.078 $426,022 $468,864 $42,842 1.10
Total Resource NO Added (TRC)$0078 $$426,022 $426,240 $218 1.00
Utility (UCT)$0078. $426,022 $426,240 $218 1.00
23 The “billing history”provided in response to discovery did not separately identify weatherization participants
and weatherization non-participants.Accordingly,it was not possible to determine the disparate impact of this
methodological flaw on participants and non-participants.
20 I a g e
Ratepayer Impact (RIM)$0.169 $916,860 $426,240 -$490,260 0.46
Participant (PCI)$0.065 $355,470 $846,308 $490,838 2.35
Lifecycle Revenue Impact $0.00001075
In contrast,the Restated Table 23 inserts the upper range of savings into the calculation of benefits
including the non-energy benefits.
Restated Table 23 Using Upper Bound of Savings Estimate (1,643 kWh):Program Cost-Effectiveness
Summary for 2007—2009 (CAPAI-1-19)
.Levelized $/..Benefit /CostCost-Effectiveness Test Costs Benefits Net Benefitskwh Ratio
Total Resource +Conservation added (PTRC)$0078 $426,022 $622,141 $196,118 1.46
Total Resource NO Added (TRC)$0.078 $$426,022 $579,517 $153,494 1.36
Utility (UCT)$0078.$426,022 $434m571 $8,548 1.02
Ratepayer Impact (RIM)$0.169 $916,860 $434,571 -$482,289 0.47
Participant (PCT)$0065 $355,470 $846,308 $490,838 2.36
Lifecycle Revenue Impact $000001057
As can be seen,with or without the non-energy benefits,using the upper bound rather than the mid
point,the low-income weatherization is likely to be cost-effective,even under the Cadmus study,using
every test but the RIM test,and without making any corrections to the Cadmus analysis.
Similar results are found when one considers the upper bound of the arrearage reduction estimate.
Under this restatement,Table 21 would not change since it does not incorporate non-energy benefits.A
restated Table 23,however,finds that low-income weatherization is cost-effective under both Total
Resource Cost tests,as well as under the Participant cost test.While low-income weatherization still
would not reach a benefit-cost ratio of 1.0 under the Utility Cost Test in this restated Table 23,this
failure occurs because,as discussed in detail above,Cadmus erroneously assigns no utility cost savings
(e.g.,reduced working capital,reduced bad debt,reduced credit and collection savings)to a
weatherization participant’s reduction in arrears and dollar increase in payments and assume that
arrearage reductions occur only in Year One and not in subsequent years.
21 I P a g e
Restated Table 23 Using Upper Bound of Arrearage Reduction ($54):Program Cost-Effectiveness
Summary for 2007 —2009 (CAPAI-1-20)
While not asked to produce a restated Table 23 incorporating the upper bound for BOTH the arrearage
reduction AND usage reduction,the combination of the two impacts,both of which increased benefit-
cost ratios to more than 1.0,would increase the benefit-cost ratios under each test even more.
In setting forth these restated tables,no other adjustments or corrections to the Cadmus analysis have
been made.The need for such other adjustments and corrections,however,has been documented
throughout these comments.These adjustments and corrections would be expected to increase the
cost-effectiveness of the Company’s weatherization program beyond that identified immediately above
in these restated tables.
The ultimate finding of CAPAI in this proceeding is that the Cadmus study provided by Rocky Mountain
Power Company provides an inadequate basis upon which to conclude that the Rocky Mountain Power
low-income weatherization program is not “cost-effective.”In fact,had the model used by CADMUS
been properly formatted and sufficient,legitimate and necessary input data been input to the model,
CADMUS would have had no choice but to find the program amply cost-effective.The following findings
are appropriate given the data and discussion provided above:
1.The Cadmus study failed to adjust for the disproportionate impact of price hikes and economic
recession on non-participants.The price increases and economic recession facing Idaho
residents in the study period have had a disproportionate impact on non-participant usage
reduction.
2.The Cadmus study failed to account for the lower persistence rate of usage reduction actions
taken by non-participants in response to price increases and economic recession.As a result,
Levelized $1 Benefit I CostCost-Effectiveness Test Costs Benefits Net Benefitskwh Ratio
Total Resource +Conservation added (PTRC)$0078 $426,022 $531,329 $105,306 1.25
Total Resource NO Added (TRC)$0.078 $426,022 $497,509 $71,486 1.17
Utility (UCT)$0078.$426,022 $352,563 -$73,460 0.83
Ratepayer Impact (RIM)$0.169 $815,476 $352,563 -$462,913 0.43
Participant (PCT)$0.065 $355,470 $744,924 $389,454 2.10
Lifecycle Revenue Impact $000001075
22 P a g e
the study failed to incorporate increases in the difference in savings between participants and
non-participants over time.
3.The Cadmus study failed to distinguish between heating and non-heating participants and non-
participants.
4.The Cadmus study failed to account for the fact that energy assistance in Idaho is delivered
exclusively to the vendors of a household’s primary heating fuel.Accordingly,the selection of
non-participants based on their receipt of energy assistance would result in comparing a
population of non-participant electric heating customers against a population of combined
heating and non-heating customers.
5.The Cadmus study failed to account for the fact that non-participants had a higher rate of
disconnections for nonpayment,as well as a higher proportion of customers experiencing any
disconnections,which would not result in a reduction in the number of billing days or billing
months.The reduction in sales/usage attributable to days on which service was disconnected
would inappropriately appear as a “usage reduction”in the non-participant population.
6.The Cadmus study failed to account for the fact that a significant number of non-participant
homes would have received federally-funded weatherization services prior to the study period.
As a result,the savings for these homes would have been increased relative to previously
unweatherized program participants,due to the increased ability of households to control their
energy consumption.
7.The Cadmus study inappropriately found that arrearage reductions were a one-time,first year,
impact rather than an annual impact.The impact of reduced arrearages should be considered
over time, not merely in the first year.
8.The Cadmus study failed to assign any utility cost savings to reduced arrearages,reduced
numbers of service disconnections for nonpayments,and an increased number and dollar value
of participant payments.Cadmus failed to account for fundamental cost savings such as
reduced working capital,decreased bad debt,reduced and redeployed credit and collection
activities,and reduced lost sales.
9.The Cadmus study failed to account for the fact that an increased proportion of non-participant
payments were directed toward bills other than for current usage.Non-participant payments
were disproportionately devoted to customer service fees such as late payment charges,
reconnect fees,field collection fees,and the like.
10.The Cadmus study failed to ensure that all “post-installation”data actually represented time
subsequent to the installation of weatherization measures.Including pre-installation data on
23 I
usage and payments/arrears has the impact of reducing the calculated impact of the
weatherization measures.
11.The Cadmus study inappropriately included monthly bill credits as a reduction to arrears.An
account with a bill credit in any given month has a $0 arrears,not a negative arrears.
The direction of the impact that these corrections would have on the calculation of cost-
effectiveness is identified in the Table below.
Given these adjustments and corrections,and given further how close the low-income
weatherization programs comes to a 1.0 benefit-cost ratio even under the flawed Cadmus analysis,
and given finally how the low-income weatherization program reaches a benefit-cost ratio of 1.0
with savings within the confidence interval of the Cadmus study even as it stands,making these
adjustments and corrections could reasonably be expected to have yielded a positive benefit-cost
ratio for the Rocky Mountain Power weatherization program.
24
Part 2:The Necessary Components for a Cost-Effectiveness Analysis.
In this section of CAPAI’s comments,CAPAI identifies the basic approach that should be used to
determine the cost-effectiveness of low-income weatherization.Indeed,the basic approach used by
Cadmus in the evaluation of the cost-effectiveness of the Rocky Mountain Power low-income
weatherization program is,fundamentally,a sound approach.A benefit-cost analysis should consider
pre-and post-installation changes in customer behavior for a participant and non-participant
population.The differences between those two populations would represent the net change in
customer behavior attributable to the weatherization program.
The recommendations below,of course,assume the methodological and data corrections to the
Cadmus study identified in Part 1 above.These general recommendations are over and beyond the
recommended corrections to the specific changes identified as being necessary to correct flaws and
omissions in the Cadmus Rocky Mountain Power study.
The following changes in the Rocky Mountain Power approach,however,are merited:
1.Separate cost-effectiveness determinations should be made for heating and non-heating
customers.It is inappropriate to mix heating and non-heating participants and non-participants
into a single cost-effectiveness determination.
2.It certainly is inappropriate to compare a heating non-participant population to a non-heating
participant population or to a population containing a mixture of heating and non-heating
customers.
25 Z a e
3.A cost-effectiveness determination should reflect the differences between weatherized and
non-weatherized homes.Previously weatherized homes,whether or not weatherized with non-
utility resources and whether or not weatherized during the study period,should not be
included in the non-participant population.
4.The Utility Cost Test (UCT),Total Resource Cost test (TRC),and Ratepayer Impact test (RIM)
should all include the cost savings attributable to changes in the arrearages,payment patterns,
payment levels,and collection patterns of weatherized homes relative to non-participant
homes.An avoided bad debt or working capital expense,in other words,is as much a utility
cost savings as an avoided energy or capacity expenditure.Reductions in arrearages,as well as
changes in payment patterns,payment levels and collection patterns are not merely “societal”
benefits.
5.Payment cost savings attributable to usage reduction should be calculated as annual savings,not
merely as a one-time first-year savings.Determining the stream of savings over the life of the
weatherization measures,discounted to present value,is appropriate.
6.The societal non-energy benefits (NEB5)such as increased comfort,decreased homelessness,
increased health and safety,and the like,are separate from and in addition to the payment-
related benefits accruing to the benefit of the utility (and its ratepayers).While benefits such as
reduced working capital and bad debt would apply to the Utility Cost Test,Ratepayer Impact
Test,and Total Resource Cost test,benefits such as improved health and economic development
would apply only to the Total Resource Cost Test.
7.A cost-effectiveness test should consist of three components:(1)the energy and demand
avoided costs (i.e.,traditional avoided costs);(2)the payment-related avoided costs (e.g.,bad
debt,working capital,etc.);and (3)the societal savings (e.g.,environment,health,comfort,
etc.).
Because much of the value-added presented by CAPAI in this section of its comments relates to the
consideration of the payment-related ratepayer benefits generated by low-income weatherization,
CAPAI offers these special observations about such benefits:
The payment-related benefits of low-income weatherization programs have been recognized for many
years.These benefits have been seen as delivering real dollars of cost reductions to utilities.One Oak
Ridge National Laboratory (ORNL)study, for example,observed in 1994:
26 I P i g e
Because of characteristics of household members and the nature of energy conservation
measures in a low-income DSM program,a number of other cash-flow benefits accrue
to electric and natural gas utilities as a direct result of implementing these programs.
For example,to the extent that the energy bills of low-income households are reduced
as a result of running DSM programs,the more likely that arrearages will be reduced.
Arrearage reductions,in turn,lead to costs savings for utilities.These savings typically
include reductions in bad debt write-offs,lower collection costs,lower termination and
reconnection costs,and possibly financing costs for accounts receivable.24
Oak Ridge continued on to note:
[Am important by-product of running low-income DSM programs is the reduction in
arrears experienced by utilities from low-income households.That reduction,of course,
is a benefit to the utility —i.e.,it favorable affects cash flow...[l]ncluding that amount as
a benefit improves the benefit-cost ratios for both the incremental and inclusive
versions of four of the tests.25 The exception is the Participant Test.26
Oak Ridge then recommended:
Arrearage reductions from running a low-income DSM program result in estimable,
administrative savings for a utility.Although available evidence suggests a wide range
of possibilities for the value of these administrative savings attributable to arrearage
reductions across the country,individual utilities can estimate the amount through
billing analysis.We recommend that such estimates be included as part of the benefits
of running a low-income DSM program.They should be treated the same as avoided
energy and capacity costs of running a program.27
CAPAI urges the Idaho Commission to adopt this ORNL recommendation and reasoning.
‘ns to Qu ‘avment-’
Some analysts fail to incorporate payment-related benefits because they assert either that the data
does not exist to accurately determine a quantifiable benefit or that the added value generated by these
“non-energy benefits”is insufficient to justify the effort to pursue such a quantification.(see,CAPAI-1-
49(d)).Unfortunately,these analysts do not distinguish between the “societal”non-energy benefits
(such as reduced homelessness,increased health and safety)and the utility-related cost reductions
associated with changes in payment amounts and payment patterns.The Oak Ridge National
24 Marilyn Brown and Lawrence Hill (May 1994).Low-Income DSM Programs:MethodologicalApproach to
Determining the Cost-Effectiveness of Coordinated Partnerships,ORN L/CON-375,Oak Ridge National Laboratory:
Oak Ridge (TN).(hereafter MethodologicalApproach).
25 The reference to “four of the tests”includes the standard benefit-cost tests,including:(1)the Societal test,(2)
the Ratepayer Impact test,(3)the Total Resource Cost test,and (4)the Utility Cost Test.
26 Id.,at 5.11.
27 Id.,at 6.2.
27 I P a g e
Laboratory (ORNL) study of non-energy benefits offered a point analysis (as well as a range-analysis)28 of
documented payment-related savings. In the absence of information to the contrary, it would be
reasonable to incorporate these Oak Ridge point estimates (escalated to current year dollars) into a
cost-benefit analysis.
In the alternative, just as environmental benefits are not quantified on a separate per-unit basis, but are
instead incorporated through an environmental percentage "adder," the non-energy benefits unique to
low-income programs can be incorporated through a percentage "addet' as well if the Commission
believes that a calculation of per-unit savings is not practicable. The seminal study of the use of such
adders concluded that "a cost-effectiveness adder of 50 percent of avoided costs for all low-income
DSM programs" was justified by the existing empirical data.29 The Howat analysis concluded that
"analysts have thus reached their justification of 50 percent in different ways,30 but are able to reach a
consensus that 50 percent of avoided cost is a reasonable and appropriate adder for low-income DSM
programs."
While CAPAI believes that incorporating the Oak Ridge dollarized benefits per program participant is a
reasonable approach to incorporating payment-related non-energy benefits, using an "addet' in the
same fashion as the environmental adder is used is a reasonable second-best alternative.
28 For example, the "range of benefits" found for "reduced carrying costs on arrears" was between $4 and $110
per participating household in Net Present Value terms, with the "point estimate" being $57 per participating
household. Oak Ridge, supra, at 6.
29 John Howat et al. (April 1999). Analysis of Low-Income Benefits in Determining Cost-Effectiveness of Energy
Effciency Programs, National Consumer law Center: Boston (MA).
30 The Howat analysis presented a menu of avoidable costs with separate percentage "adders" assigned to each set
of costs. The "variety of ways" referenced in the conclusion simply refers to the fact that different people could
select different avoided cost components, but any such set of reasonable selections would ultimately generate
support for an adder of 50% or more.
28 I P il