20141016Comments.pdf

Benjamin I. Otto (ISB No. 8292)
710 N 6'h Street
Boise,ID 83701
Ph: [phone] xt2
Far [phone]
[e-mail]
Attorney for the Idaho Conservation League
IN THE MATTER OF THE
APPLICATION OF PACIFICORP DBA
ROCKY MOUNTAIN POWER FOR
AUTHORITY TO MAKE REVISIONS
TO ITS ELECTRIC SERVICE
SCHEDUTE I55, AGRICULTURAT
ENERGY SERVICES
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BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
CASE NO. PAC-E-14-08
IDAHO CONSERVATION LEAGUE
COMMENTS
The Idaho Conservation League (ICfecommends the Commission approve Rocky
Mountain Power's (RMP) application, subject to some minor changes described below. Overall,
RMP's request is a commendable effort to refine the non-residential efficiency programs. ICL
appreciates and supports RMP's effort to expand participation and improve energy savings by
streamlining programs, revising incentive levels, adding important new programs, and targeting
the notoriously hard to reach small commercial class. The proposed changes will help close the
gap between the "cost-effective" and "achievable" levels of energy efficiency potential, which
demonstrates RMP is following this Commission's direct to pursue all cost-effective energy
efficiency. Finally, RMP's application addresses Order 32890 where the Commission directed
RMP to "increase its efforts towards achieving higher levels of cost-effective DSM." Order No.
32890 at 12.
PAC-E-14-08
ICL COMMENTS
October 16,2014
The American Council for an Energy-Efficient Economy (ACEEE) recently surveyed the
best preforming efficiency programs around the country.' This report identified key trends
emerging in well-run utility efficienry programs, including: targeting customer sub-segments,
adapting core programs to changing markets and standards, streamlining customer
communications, and providing "one-stop shopping" for customers. ACEEEat 8 - 9. RMP's
proposed changes reflect these key trends and build upon proven successes in other states. At the
most basic level, combining the existing separate programs into a single wattsmart Business
program will assist customer understanding and should reduce RMP's administrative burdens.
The Commission should commend RMP for applylng best practices from leading programs.
RMP's application and testimony set forth five categories of changes. The remainder of
these comments addresses each category and recommends the Commission adopt RMP's
proposals subject to some small changes.
Consolidate Non-Residential Efficiency Programs into the Wattsmart Business Program
As noted above, ICL supports this change because it will improve customer
understanding and likely reduce RMP's administrative costs. ICL supports providing customers
with a single point of contact within RMP, enabling a seamless transition between program
offerings, and allowing customers with different accounts to use one program. Hymas Direct at 3.
However, ICL opposes RMP's proposal to discontinue to the New Construction Design
Assistance, Design Honorarium, and Design Incentive programs. Id at 5. Low program
participation is not a reason to disband a program, assuming it is cost-effective. ICL recommends
the Commission allow RMP to continue to offer these programs in the combined wattsmart
Business portfolio.
I S. Nowack et. al. , Leaders of the Pack: ACEEE's Third National Reyiew of Exemplary Energy
Efficiency Programs,lune 2013. (available at: http://www.aceee.org/research-reportlil32).
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ICL COMMENTS
October 16,2014
RMP also proposes a more flexible approach to describing program offerings,
participation criteria, and incentives. Hymas Direct at 10 - 1 1 . ICL supports, in general, balancing
clarity and consistency for customers with an efficient way for RMP to adapt program offerings.
Allowing utilities to provide details outside of a Commission approved tariffdoes provide more
flexibility to RMP. tCL submits the typical customer likely doesn't delve deeply into utility tariffs,
so providing information through websites and other communications is likely more effective.
ICL's concern is that RMP's proposed procedure to make program changes does not allow for
public involvement until late in the process. Exhibit 3 shows a flow chart for proposing,
reviewing, and approving program details not included in the tariffs Hymas Direct, Exhibit 3. ICL
proposes the Commission modifr RMP's proposal slightly to allow for stakeholders to review and
comment on proposed changes at the same time as Commission Staff. This need not be a formal
comment process before the Commission; rather an informal comment opportunity provided by
the Company is sufficient.
Update Incentive Levels for Some Measures or Programs
ICL supports the proposal to raise the funding cap to 70o/o of project costs, increase the
incentive levels, and allow projects to combine prescriptive and custom incentives. Id. Increasing
incentives and allowing these to cover more of the total project costs will clearly be more
attractive to customers. Combining perceptive and custom incentives should enable deeper
energy savings in a single project. ICL supports these changes because they reflect a best practice
seen byACEEE-adjusting program offering to adapt to changing markets. While RMP states that
increasing incentive levels results in a preliminary Utility Cost Test result below 1.0, ICL agrees
with RMP's explanation that current modeling may not capture all the energy benefits. Id at 17.
These changes pass the Total Resource Cost Test with a score of 2.53. Id Exhibit 2, Page 10.ICL
recommends the Commission approve these changes.
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ICL COMMENTS
October 16,2014
Offer Energy Management Services
ICL strongly supports RMP's proposal to compliment "capital-based" projects with a new
offering for Energy Management services. Hymas Directat 8. One problem with traditional
capital, or widget-based, programs is uncertainty of maintaining energy savings through the
assumed useful life of the measure. An Energy Management offering can help address this
problem by establishing the labor and processes to ensure buildings and processes continue to
operate efEciently. In this way, the offering leverages other capital-based programs and can help
ensure Idahoans get the energy savings they are payrng for. Anecdotally ICL has heard Simplot
energy managers describe their efforts to unlock greater savings from both better operations and
changing employee behaviors. ICL notes that RMP's proposal will result in measurable changes
to energy use, which allows the Commission and others to ensure this is a cost-effective offering.
Idat9.
ICL acknowledges RMP's initial assessment shows the Energy Management Offering has a
Total Resource Cost result below 1.0. Hymas Direct, Exhibit 2 at 10. However, RMP notes this
result can be attributed to uncertainty regarding the customer implementation costs. Hymas
Directat 17. From the utility perspective, the offering is cost effective with a Utility Cost Test
result of 1.01. Id, Exhibit 2 at 10. ICL submits this offering is a prime example when considering
the portfolio level results in most informative. As stated above, Energy Management is could
leverage additional savings from capital based projects. Overall, the wattsmart Business portfolio
passes the four main cost effectiveness tests. Id. Moreover, the Energy Management offering will
provide measurable results allowing the Commission and others to ensure the actual program
performance is cost efflective.
ICL also supports the RMP's proposal to co-fund an onsite energy manager for qualifring
customers. Hymas Direct at 6 - 8. Assisting businesses with the expertise and labor necessary to
PAC-E-14-08
ICL COMMENTS
October 16,2014
operate an effective energy management program is an important way to increase customer
participation and energy savings. RMP's proposal includes important cost containment
provisions that ICL believes are necessary to ensure an effective, equitable program. Specifically,
RMP proposes to limit the incentive to the lesser of the customer's actual pay and overhead, or
the prescriptive incentive level. RMP also proposes to require customers to meet specific energy
saving goals or repay the incentives. Combined, these features should ensure the program results
in incentives paid for verified energy savings. Assuming the savings goals are set to deliver
benefits that exceed the costs, this will ensure a cost-effective program. Lastly, ICL notes that
RMP assumes no additional energy savings will result from an onsite energF manager. This is a
highly conservative estimate, as merely having someone focused on energy will almost certainty
result in savings from simple things like turning offlights, or addressing malfunctioning
equipment. Because Energy Management will leverage traditional capital-based programs, and
requires the labor and knowledge to save energy, ICL recommends the Commission approve
RMP's proposal.
Update Prescriptive Incentives
The ACEEE report emphasized that a key trend in the best preforming utility programs is
a continual effiort to adjust programs to meet changing market conditions. ACEEE at 9. Overall,
ICL supports RMP's proposals described in Exhibit 5, although we do not have the technical
capacity to review each change in detail. To the extent the proposed changes reflect deemed
savings from the Regional Technical Forum or adopted codes and standards, ICL submits these
are appropriate. ICL specifically supports a few changes: grouping LED bulbs into a single
category as this should reduce program overhead and increase customer clarity; changing
lighting control incentives to address the watts covered instead of sensors installed; and removing
screw-in CFLs. Hymas Direct, Exhibit 5 at 1 - 2. However, ICL is concerned that RMP changed
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ICL COMMENTS
October 16,2014
the baseline for fluorescent lighting retrofits. Hymas Directat 12. RMP explains this change is due
to updated federal lighting standards. ICL supports updating programs to reflect changing codes.
However, the key question is about timing. Updating the baseline should depend on the lighting
installed in RMP's Idaho service territory, rather than a change in the standard. ICL recommends
the Commission require RMP to document their Idaho business customers have actually
converted from T12 to more efficient lights.
Small Business Offering
ICL strongly supports RMP's proposal to offer a new program targeting small businesses.
This category is notoriously hard to reach due to the diversity, tight cash flows, and relatively low
savings per project. ICL reviewed RMP's 2013 Efficiency Potential Study and confirms, as a
group, small businesses provide a huge potential to increase energF savings. The ACEEE report
found that several of the examples RMP sites are the best performing small business programs in
the country. ACEEE at 11. RMP's proposal reflects many of the best practices including providing
a lighting tool with detailed results, using approved contractors already working in the areas, and
addressing the capital and cash flow needs. Hymas Direct, Exhibit 6 at 3. While ICL strongly
supports RMP's proposal, we submit the Company should include additional measures beyond
lighting, specifically measures to address office equipment as well as heating and cooling needs.
This program will connect businesses with energy saving contractors and once this relationship
begins, RMP should encourage both parties to wring the maximum amount of savings from each
interaction. ICL recommends the Commission approve this program and encourage RMP to
expand the offered measures.
Conclusion
ICL commends RMP for proposing important changes to their non-residential programs.
These changes demonstrate that a thoughtful, engaged utility can take actions to really pursue all
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ICL COMMENTS
October 16,2014
cost effective energy efficiency. RMP's proposals, overall, reflect best practices of leading
programs around the country. ICL recommends the following:
. Approve the consolidation of non-residential programs into wattsmart Business
Allow a flexible tariffprovided that stakeholders may comment on changes in the same
manner and timing as Commission Staff
Approve the Energy Management Offering including the co-funding of an onsite energy
manager
Approve updated prescriptive incentives based on revised RTF savings and changes in
codes and standards actually reflected in RMP's Idaho service territory
Approve the Small Business Offering and encourage RMP to add additional measures
beyond lighting
Respectfully submitted this l6'h day of October, 2014,
Benjamin f. Otto
Idaho Conservation League
CERTIFICATE OF SERVICE
I certiff that on the 16nd day of October,2014,I delivered true and correct copies of the
foregoing COMMENTS to the following persons via the method noted:
Hand delivery:
Jean Iewell
Commission Secretary (Original and seven
copies provided)
Idaho Public Utilities Commission
427 W. Washington St.
Boise,ID 83702-5983
PAC-E-14-08
ICL COMMENTS
Electronic Mail:
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
Benjamin J. Otto
October 16,2014