20141114Comments.pdf

Benjamin l. Otto (ISB No. 8292)
710 N 6'h Street
Boise,ID 83701
Ph: [phone] x12
Fax: [phone]
botto@idahoconservation. org
Attorney for the Idaho Conservation League
IN THE MATTER OF THE
APPLICATION OF ROKCY
MOUNTAIN POWER REQUESTING
PRUDENCY DETERMINATION ON
DEMAND-SIDE MANAGEMENT
EXPENDITURES
?0!! H0v
BEFORE THE IDAHO PUBLIC UTITITIES COMMISSION
PFI 3: 28
CASE NO. PAC-E-14-07
IDAHO CONSERVATION LEAGUE
COMMENTS
The Idaho Conservation League ("ICL") recommends the Commission approve Rocky Mountain
Power's ("RMP") request. The application, testimony, exhibits, and production responses
demonstrate that RMP prudently operated the Demand-Side Management ("DSM") programs
dwing 2010, 2011,2012, and 2013. Below ICL discusses some instances where RMP's
programs did not meet cost-effectiveness thresholds and made prudent changes to address this
issue. Also, in some years, RMP experienced declining participation and savings achievements,
but the Company appears to have instituted prudent program reforms to recti$ these issues.
Overall, ICL commends RMP for acquiring energy savings during the2010-2013 that are l35o/o
of the Integrated Resource Plan selected targets.
Commercial and Industrial programs
RMP offers two programs in this sector, Energy FinAnswer and Energy FinAnswer
Express. Overall, these programs were cost effective in each year. While FinAnswer Express
savings dipped 35oh from 2010 to 2011, RMP states that in 2010 savings increasedby 322%
from 2009 attributable to a boom in projects at schools.l Overall savings increased by 35%
during the 2010 to 2013 period. ICL also notes that RMP included a point-by-point action plan in
t H).mas Exhibit L at26-27.
PAC-E-14-07
ICL Comments
November 14,2014
response to a process and impact evaluation.2 Continued cost effectiveness, increasing savings,
and the action plan all point to a prudently operated program.
RMP also offlers FinAnswers for large customized efficiency projects. This program was
cost effective in each year. However, program savings dropped dramatically from 2010 to 2012.
In 2013 savings responded strongly to 36%o above 2010 levels. ICL reviewed RMP's point-by-
point action plan responding to a process and impact evaluation.3 This response shows a
proactive effort by RMP to improve the tracking of savings and customer engagement.
Continued cost effectiveness, increasing savings, and the action plan all point to a prudently
operated program.
Agricultural Programs
RMP offers the Agricultural Energy Service progftlm to find energy savings in the
irrigation sector. While generally cost effective, in 2013 RMP discovered certain prescriptive
measures no longer based the Total Resource Cost threshold.a Upon this discovery, RMP applied
to change the program offering to drop the non-cost effective measures and retain the cost-
effective system design offering. ICL believes this is a prudent response to the situation. Overall,
savings increased during the2010-2013 timeframe and delivered cost effective savings.
Residential Programs
RMP offers two residential programs, See Ya Later Refrigerator and Home Energy
Savings. While cost effective during each year, energy savings have declined in both programs
during the 2010 to 2013 time period. In the refrigerator program ICL notes RMP's efforts to
expand cross promotion with retailers and direct mail advertising. However, these efforts do not
appear to be sufficient as participation ad savings continue to decline year over year. ICL is
encouraged by the new effort mentioned in the 2013 annual report to direct program information
to purchasers of new refrigerators who receive an incentive and recognize communities that
recycle the most units.s While we are discouraged by the decline in energy savings, these efforts,
'Hymas Exhibit I at 480 - 481.
'H),mas Exhibit I at 481 - 482.
n H)rmas Direct at14,20.
5 Hymas Exhibit I at33l - 334.
PAC-E-14-07
ICL Comments
November 14,2014
combined with the point-by-point action plan responding to process and impact evaluations6,
indicate a prudently run program.
The Home Energy Savings program offers a variety of incentives mostly for appliances.
The program was cost-effective in each year. Energy savings has dropped3l% over the period.
However, ICL notes RMP's action plan in the 201I report expanding retailer outreach and co-
brandingT; the 2012 report action plan to add LED bulbs and overall branding under Wattsmart8;
and 2013 communication plan to adopt electronic incentive application processing.e These yearly
efforts to address declining participation and energy savings indicate prudent program
administration.
Low Income Weatherization
This program continues to experience challenges t deliver cost-effective savings. ICL
participated in the low-income program workshops under docket GNR-E-12-01. We are
encouraged RMP adopted many of the recommendations developed through that process. We are
also encouraged RMP continues to work with the local Community Action Partnership agencies
to find ways to increase savings and reduce costs.l0ICL specifically notes RMP is awaiting the
results of an updated evaluation of program years 2010-2012 that should include methods to
further improve these programs.l' Becarrse RMP is actively working to improve the program,
and low-income weatherization serves a critical need for Idahoans, ICL recommends the
Commission find these expenses prudently incurred.
Northwest Enerry Efficiency Alliance
ICL believes that prudent utility sponsored energy efficiency should go beyond
traditional measures and programs to include market transformation activities. Transforming the
market place to ensure companies develop and offer highly efficient products is critical to ensure
a long-term path towards pursuing all cost effective energy efficiency. In our region, the
Northwest Energy Efficiency Alliance (NEEA) leads the efforts in this regard. ICL is
u H),mas Exhibit I at479 - 480.
'Hymas Exhibit L atl45.t Hymas Exhibit L at271 - 276.
'Hymas Exhibit 1 at 348.
'o Hymas Direct at 15 - 17.
" Hymas Direct at2l.
PAC-E-14-07
ICL Comments
November 14,2014
disheartened RMP declined to participate in NEEAs 2010 - 2014 and2015 - 2019 cycles. After
reviewing RMP's response to Staff Production Request 4,ICL acknowledges RMP's reasons for
this decision. It rings true that RMP's Idaho service territory and customer type is unique from
most northwest utilities. First, Southeast Idaho is far afield from the core geography NEEA
operates in. Second, RMP's sales are dominated by the large industrial and agricultural sector
where NEEAs progftlms are not necessarily focused. However, ICL recommends the
Commission direct RMP to find other paths to pursue market transformation as part of the
obligation to pursue all cost effective energy efficiency.
In closing, ICL recommends the Commission find RMP's 2010 - 2013 DS spending
prudently incurred and the programs prudently administered. RMP responded appropriately to
the Agricultural Energy Savings program and Low Income program cost effectiveness results.
The Company offers point-by-point action plans in response to process and impact evaluations.
And RMP's outreach efforts show a continual effort to try new methods to increase participation.
Respectfully submitted this 14th day of November 2014,
Idaho Conservation League
CERTIFICATE OF SERVICE
I certifr that on the 14th day of November, 2014,1delivered true and correct copies of the
foregoing COMMENTS to the following persons via the method noted:
Electronic Mail:
Hand delivery:
Jean Jewell
Commission Secretary (Original and seven
copies provided)
Idaho Public Utilities Commission
427 W. Washington St.
Boise, ID 83702-5983
PAC-E-14-07
ICL Comments
Ted Weston
Daniel E. Solander
201 South Main, Suite 2300
Salt Lake City, UT 8411
ted.weston@pacifi corp.com
daniel.solander@pacifi corp.com
Benlamin J. Otto
Idaho Conservation League
November 14,2014