20170315Comments.pdf

Brad M. Purdy
Attorney at Law
BarNo.3472
20lg N. 17th St.
Boise,ID. 83702
[phone] (Land)
[phone] (Cell)
[e-mail]
Attomey for Petitioner
Community Action Parfirership
Association of Idaho
ISB Bar No. 3472
IN THE MATTER OF TI{E APPLICATION
OF PACIFICORP DBA ROCKY MOUNTAIN
POWER FOR PRUDENCY
DETERMINATION OF DEMAND-SIDE
MANAGEMENT EXPENDITURES
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BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
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CASE NOS. PAC.E-I6-14
COMMUNITY ACTION
PARTNERSHIP ASSOCIATION
OF IDAHO'S COMMENTS
COMES NOW, lntervenor Community Action Partnership Association of Idaho
(CAPAI) and in response to Order No. 33679, issued by the Commission in this proceeding on
December 20,1016, submits the following comments in response to the Application filed by
Rocky Mountain Power (hereinafter; "RMP" or the "Company") seeking a finding of prudency
by the Commission for the Company's investment in its entire DSM portfolio. Although RMP's
objective is to obtain a determination by this Commission that the entirety of its DSM
invesftnents were prudently incurred, CAPAI limits these comments to the Company's Low
Income Weatherization Assistance (LIWA) Program.
I. BACKGROTJI\ID.COMPAIYY'S APPLICATION
RMP's claimed results of its entire DSM portfolio for years 2014 through 2015, achieved
a positive cost-effectiveness result under both the PTRC and UCT of greater than 1.0. Even
CAPAI COMMENTS IN RESPONSE TO RMP APPLICATION: CASE PAC-E-16-14 I
though the most recent cost-effectiveness evaluation of the LIWA program for years 2010
through 2012 yielded a positive combined cost-effectiveness score, the LIWA progam was not
found to be cost effective for the years 2014 and 2015. It is these two program years that are the
subject of this pending docket. Specifically, according to Table 3,p.6,par.12, of the
Application, RMP reveals that LIWA received a score for 2014 of 0.72 under the PTRC (TRC
with a 10oZ conservation adder) and a value of 0.50 under the UCT. For the year 2015, LIWA
received a score of 0.48 under the PTRC and 0.35 under the UCT. These results constitute an
obvious reduction in LIWA's cost-effectiveness since the years 2010-2012; the latter of which
achieved a result of 1.34. See, Id. The Company's Application identified the claimed reasons
for the reduction in LIWA's cost-effectiveness as follows:
The Low lncome Weatherization program was not cost effective due to
multiple factors including a limited amount of homes served and measures
installed, but the primary driver was the reduction in decrement values
calculated in the 2015 Integrated Resource Plan ("IRP").
See, Id.
The Company notes that its LIWA program is currently undergoing a Program evaluation for the
years 2013-2015 with a published report expected in 2017 . Although this evaluation might ultimately
yield another cost-effectiveness assessment for LIWA, its primary purpose is, apparently, to examine the
LIWA program on a more holistic basis and to assess the factors contributing to the reduction in cost-
effectiveness for LIWA. It is also anticipated to yield valuable information in terms of how the program
is being operated and identifuing measures that could be undertaken to improve the program's
performance.
Finally, RMP notes that:
"[i]n Case No. GNR-E-12-01, the Commission initiated a generic case to
investigate the cost effectiveness of low income weatherization programs. The
case resulted in a myriad of Commission approved recommendations which the
Company contends it has complied with."
See, Order No. 32788, and Application, p. 6, par. 12. [Emphasis addedJ.
CAPAI COMMENTS IN RESPONSE TO RMP APPLICATION: CASE PAC-E-16-14 2
II. CAPAI ANALISYS
A. Number of Homes Weatherized
As quoted above, RMP contends that one factor reducing LIWA's cost-effectiveness
pertains to the number of homes weatherized in a given program year. ln fact, the CAP agencies
providing weatherization services to RMP customers (SEICAA and EICAP) within the CAPs'
service territories have increased the number of low-income homes weatherized in recent years
resulting in an upward trend which, based on preliminary 2016 data, is expected to continue.
CAPAI notes, however, that if additional homes are weatheized, then the cost-
effectiveness should increase as additional savings are added to the overall LIWA program. This
will assist the agencies in fully spending out their allotted utility LIWA funds.
One of the reasons that more low income homes are not receiving weatherization under
LIWA is the difficulty that SEICCA is facing in identifuing low income customers whose homes
need weatherization. This does not mean that the low-income weatherization market is already
saturated. Rather, it is the function of a need for assistance from RMP in identifuing eligible
homes and customers. In that regard, RMP has informally agreed to assist the CAP agencies in
identifring otherwise eligible low income residences that meet the requisite criteria for receiving
weatherization measures under LIWA. In fact, the market is far from saturated and CAPAI
welcomes the Company's assistance in identifring those eligible customers who could and
should receive weatherization measures.
B. Gas Prices
RMP refers to reduced gas prices as the primary driver of why the LIWA program's cost-
effectiveness has decreased. CAPAI obviously has no control over gas prices, but contends that
the current price of gas is not an impediment to a cost-effective LIWA program. This contention
CAPAI COMMENTS IN RESPONSE TO RMP APPLICATION: CASE PAC-E-16-14 J
is based on the strategy briefly summarized below focusing on matters within CAPAI and
RMP's control.
C. Changes in LIWA Program
1. Targeted Selection of High Savings Weatherization lVleasures
CAPAI is already in the process of identiffing and prioritizing the most cost-
effective and allowable weatherizationmeasures and, to the extent allowed, proposes investing
utility funds in such measures first. This targeted selection has the potential to substantially
enhance the cost-effectiveness of RMP's LIWA program. In fact, this approach, to the extent not
already implemented for a given utility, should be assessed for Idaho Power and Avista's LIWA
progftrms as well. As discussed below, CAPAI would like to form a working goup outside the
scope of this proceeding involving Staff, RMP, and other interested stakeholders to further
analyze this proposed strategy and determine how it should be implemented for RMP. As stated,
each utility could be assessed in the same manner based on that company's specific
circumstances. CAPAI proposes using the results of the program evaluation as a starting point
for this process of target selection.
2. Working Group
CAPAI proposes that a working group be formed including, at a minimum,
Commission Staff, RMP, CAPAI, and any other interested parties. CAPAI has already very
briefly broached the subject with Staffand the Company and believes that such a collaborative
process be conducted outside the scope of this proceeding. Matters that might be discussed
include: identiffing the most economically productive measures typically installed in a low-
income household, and a process by which all measures are prioritized with an eye toward how
best to dedicate utility funds for installation of the most cost-effective measures. This might
CAPAI COMMENTS IN RESPONSE TO RMP APPLICATION: CASE PAC-E-16-14 4
require a shifting between utility and federal monies to ensure that, to the extent possible, RMP
dollars are invested in relatively high energy-savings measures.
3. Gain valuable Insight from LIWA Program Evaluation
As indicated above, RMP is in the process of a "Program" evaluation for LIWA
that will be submitted to the Commission sometime later this year. CAPAI's understanding is
that such an evaluation differs from a cost-effectiveness evaluation in that the former is greater in
scope and focuses on an examination of a given DSM program identiffing its past performance,
goals for future performance, identifuing areas where the program can be achieved and areas
where it is effective and greater emphasis place on that aspect. This should be helpful in
pursuing the overall improvement of the program in terms of cost-effectiveness as well as
enhancing the overall efficacy of the program.
III. RECOMMENDATION/CONCLUSION
ln addition to any recommendations set forth above, CAPAI believes that the Company
has sufficiently justified recovery of its expenditures in the LIWA program. Furthermore,
CAPAI is fully dedicated to improving program implementation based on all of the foregoing
considerations and through anything of value proposed by the working group. CAPAI is
confident that the proposals it has included in these comments, if adopted, will have a
substantial, positive ef[ect on the overall qualrty of LIWA and its cost-effectiveness.
CAPAI appreciates the opportunity to comment on RMP's filing and the Commission's
consideration of these comments.
CAPAI COMMENTS IN RESPONSE TO RMP APPLICATION: CASE PAC-E-16-14 5
Date{ this 15ft day ofMarcb 2017.
M.
Auorney for CAPAI
CAPAI COMMENTS IN RESPONSE TO RMP APPLICATION: CASE PAC-E-16-14 6