ADVICE LETTER SUMMARY...Advice Letter No. 588-E September 3, 2019 Page 2 Specifically, Ordering...

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PacifiCorp (U 901 E)

(503) 813-7314✔[email protected]

[email protected]; reg

Pooja Kishore

588-E 2

Annual Budget Advice Letter for 2020 Energy Efficiency Programs

Compliance, Energy Efficiency✔

D.18-11-033

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CPUC, Energy DivisionAttention: Tariff Unit505 Van Ness AvenueSan Francisco, CA 94102 Email: [email protected]

Protests and all other correspondence regarding this AL are due no later than 20 days after the date of this submittal, unless otherwise authorized by the Commission, and shall be sent to:

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Pooja KishoreRegulatory Manager

PacifiCorp825 NE Multnomah Street, Suite 2000

Portland Oregon(503) 813-7314

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September 3, 2019 VIA ELECTRONIC FILING AND OVERNIGHT DELIVERY California Public Utilities Commission Energy Division Tariff Unit, 4th Floor 505 Van Ness Avenue San Francisco, CA 94102 Email: [email protected] Re: PacifiCorp (U 901-E) Advice Letter No. 588-E

Annual Budget Advice Letter (ABAL) for 2020 Energy Efficiency Programs PURPOSE PacifiCorp, d/b/a Pacific Power (PacifiCorp), submits Advice Letter No. 588-E in compliance with California Public Utilities Commission (CPUC or Commission) Decision (D.) 18-11-033 (Decision) which directs the company to submit a Tier 2 advice letter containing the budget for the next calendar year’s energy efficiency program funding levels. Through this filing, PacifiCorp requests that the Commission approve its forecasted budget for 2020 energy efficiency programs1 of $2.53 million effective January 1, 2020. BACKGROUND

I. Regulatory Requirements On September 15, 2017, PacifiCorp filed Application (A.) 17-09-010 (Application) requesting Commission authorization to continue operating its energy efficiency programs through 2020, to decrease the Surcharge to fund Public Purpose Programs (tariff Schedule S-191 designated for these programs), and to be able to adjust ongoing Surcharge collection rates via the Tier 2 advice letter process. On November 29, 2018, the Commission adopted D. 18-11-033 authorizing PacifiCorp’s requests to continue operating energy efficiency programs through 2020, to reduce the Public Purpose Program Surcharge in order to better match its energy efficiency budget with its anticipated Demand Side Management Balancing Account balance and to submit future proposed Surcharge rate changes through a Tier 2 advice letter similar to the process followed by the state’s large investor owned utilities.

1 PacifiCorp’s two approved programs are Home Energy Savings (Schedule D-118) and Wattsmart Business (Schedule A-140).

Advice Letter No. 588-E September 3, 2019 Page 2 Specifically, Ordering Paragraph 5 of the Decision requires the company to submit an ABAL for the next year’s funding levels on the first business day of September. Each ABAL shall include:

a forecast Total Resource Cost and Program Administrator Cost that meets or exceeds 1.0;

verification of prior year savings; and

a breakdown of year-to-date expenses, including at minimum the following categories: incentive payments, program evaluation, and administrative expenses.

In an attempt to more closely align PacifiCorp’s programs with those of the large investor-owned utilities, the Decision also ordered that PacifiCorp must conform to ‘Overall Portfolio Level’ metrics requirements as prescribed in Decision 18-05-0412 and other subsequent Commission guidance and decisions related to portfolio metrics submissions and filings.

Additionally, to aid the Commission’s evaluation of cost-effectiveness, in calculating its Total Resource Cost (TRC) and Program Administrator Cost (PAC), PacifiCorp must use only Database for Energy Efficiency Resources (DEER) values approved as of the date of each Annual Budget Advice Letter submission or future pleading, as applicable. PacifiCorp must also use the same adopted cost-effectiveness tools and parameters that apply to the large investor owned utilities in their submissions and filings to assess cost-effectiveness.

II. Filing Contents

PacifiCorp’s advice letter is organized as follows:

2020 Forecast Savings and Estimated Expenditures

2020 Projected Overall Portfolio Metrics

2020 Projected Cost-Effectiveness

2020 Program Changes

Verification of Prior Year Savings (2018)

Breakdown of 2019 Year-to-Date Expenses as of June 30, 2019

2018-2020 Budget and Savings Compared to PacifiCorp’s Application as approved in

Decision 18-11-033

Attachments

o Attachment 1 – PacifiCorp’s Cost Category Reporting Descriptions

2 May 31, 2018 Decision Addressing Energy Efficiency Business Plans for eight program administrators including four investor-owned utilities: Pacific Gas and Electric Company, San Diego Gas & Electric Company, Southern California Gas Company, and Southern California Edison Company; three regional energy networks (RENs): BayREN, SoCalREN, and Tri-County REN; and one community choice aggregator: Marin Clean Energy (MCE).

Advice Letter No. 588-E September 3, 2019 Page 3

o Attachment 2 – Overall Portfolio Metrics – Hard-to-Reach Reporting Descriptions

o Attachment 3 – Cost-Effectiveness Analysis

o Attachment 4 – Database of Energy Efficiency Resources (DEER) Net-to-Gross Values

o Attachment 5 – Description of PacifiCorp Cost-Effectiveness Modeling Tool

o Attachment 6 – PacifiCorp’s Program Change Process – Wattsmart Business

III. Staff Engagement

PacifiCorp appreciates the support and guidance provided by Staff of the Energy Efficiency branch as the company prepared this filing. In addition to ongoing e-mail communication, the company met with Staff on February 24, 2019 to discuss overall portfolio metrics reporting. As a follow-up, PacifiCorp provided its cost category reporting descriptions to Staff on May 24, 2019 (included in this filing as Attachment 1) and had additional meetings with Staff on July 29, 2019 and August 22, 2019 to discuss and review PacifiCorp’s draft ABAL filing. DISCUSSION In Decision 18-11-033, the Commission approved the Application of PacifiCorp to continue administering its two energy efficiency programs from 2018 through 2020.3 Taken together as a portfolio, the company’s programs have a forecast total resource cost and program administrator cost that exceeds 1.0 in 2020 as well as for the 2018-2020 period. In compliance with Decision 18-11-033, PacifiCorp also provides verification of 2018 savings results and the breakdown of 2019 year-to-date expenses, allowing staff to see the percentage associated with incentive payments, program evaluation and administrative expenses. PacifiCorp also provides the overall portfolio metrics for the 2020 forecast. In calculating its Total Resource Cost and Program Administrator Cost, PacifiCorp used only Database for Energy Efficiency Resources values approved as of August 1, 2019. As provided for in Decision 18-11-033, PacifiCorp used its cost-effectiveness model, which uses the same adopted cost-effectiveness tools and parameters that apply to the large investor owned utilities in this filing to assess cost-effectiveness relative to PacifiCorp’s electric system.

I. 2020 Forecast Savings and Estimated Expenditures PacifiCorp’s programs are still projected to exceed the 2018-2020 savings target and the 2018-2020 expenditure forecast is within 3% of the 2018-2020 forecast in the company’s approved

3 A three-year budget cycle was determined to be appropriate given the small size of PacifiCorp’s service area in California. Due to the small size of the service area, there is a lack of forecast diversity for energy efficiency programs and there can be variations in participation from year to year, particularly in the Wattsmart Business program.

Advice Letter No. 588-E September 3, 2019 Page 4 Application. The 2020 projections assume changes planned for the programs are in place on January 1, 2020.

Table 1 below shows the 2020 savings forecast (net savings at the generator) and estimated 2020 expenditures (spending budget request). Table 1 was compiled using the ‘ABAL Templates and Charts’ provided by Staff.4

Table 1 - 2020 Net Savings Forecast and Estimated Expenditures

4 Detailed footnotes 2-5 in Table 1 are not included in this filing, as they are not applicable to PacifiCorp.

Sector Program Year (PY) Budget

PA forecast

kWh

PA forecast

kW

Residential (incl allocation of non‐eval portfolio costs) $1,152,985 1,118,494 195

Commercial (incl allocation of non‐eval portfolio costs) $767,190 1,898,333 331

Industrial (incl allocation of non‐eval portfolio costs) $181,294 462,939 81

Irrigation (incl allocation of non‐eval portfolio costs) $237,911 568,271 99

Emerging Tech na na na

Public na na na

WE&T na na na

Finance na na na

OBF Loan Pool na na na

IOU Subtotal $2,339,379 4,048,037 706

ESA Savings na na

IOU Total Program Savings (w/out C&S) 4,048,037 706

CPUC Program Savings Goal na na

Forecast savings as % of CPUC Program Savings Goal na na

Codes and Standards $0

IOU EM&V $192,152

IOU PY Spending Budget Request1

$2,531,531

(LESS) IOU Uncommitted and Unspent Carryover Balance2

na

IOU PY Budget Recovery Request3

na

IOU Authorized PY Budget Cap (D.18‐05‐041) na

CCA PY Budget Recovery Request (excl. CCA Uncommitted/Unspent Carryo na

REN PY Budget Recovery Request (excl. REN Uncommitted/Unspent Carryo na

Total PA (IOU+CCAs+RENs ) PY Recovery Budget5 na

IOU Forecast PY TRC 1.11

IOU Forecast PY PAC 1.51

For reference only

REN EM&V PY Budget $0

CCA EM&V PY Budget $0

EM&V PY PA Budget total $192,152

PA Unspent Committed funds (from all prior PY through December 31, 2018 na

PacifiCorp

PA PY 2020 FORECAST

ENERGY SAVINGS


A. 2020 Budget Recovery

The budget recovery fields in Table 1 are marked as “not applicable” because at this time, PacifiCorp does not anticipate the need to modify the public purpose charge to fund PacifiCorp’s energy efficiency programs for 2020. Revenue collected to fund PacifiCorp’s energy efficiency programs is managed through the collection of the Public Purpose Charge (Schedule S-191) and tracked in the company’s Demand Side Management Balancing Account.

Decision 18-11-033 approves PacifiCorp’s request to file a Tier 2 advice letter for future proposed adjustments to the Public Purpose Charge to keep the balancing account in balance.5

“It is reasonable to approve, with modifications, PacifiCorp’s request to submit future proposed Surcharge rate changes via a Tier 2 advice letter. The modifications we adopt will further align PacifiCorp with the large IOUs and will assist the Commission in considering future applications by PacifiCorp for authorization to continue or alter its energy efficiency programs.”

The company completed a preliminary review of the current Demand Side Management Balancing Account as of June 30, 2019 and forecast expenditures and revenue through December 31, 2020. Based on this review, an adjustment to the Public Purpose Charge (Schedule S-191) is not needed at this time. Annual Public Purpose Charge revenue should remain less than annual expenditures to bring the account into balance. PacifiCorp anticipates an increase to the Public Purpose Charge will be needed effective January 1, 2021 and anticipates filing for this adjustment via a Tier 2 Advice Letter in the second quarter of 2020. Table 2 below shows the 2020 savings forecast (gross savings at the generator) and estimated expenditures.6

Table 1 - 2020 Gross Savings Forecast and Estimated Expenditures

5 In re Application of PacifiCorp (U901E), an Oregon Company, to Continue its Energy Efficiency Programs and the Surcharge to Fund Public Purpose Programs, A. 17-09-010, D. 18-11-033 (Nov. 29, 2018), p. 17, Conclusion of Law ¶3. 6 Table 2 is presented in the same format used in PacifiCorp’s past annual reports.

ProgramkWh/Yr Savings

(gross at site)kWh/Yr Savings

(gross at generation) ExpendituresHome Energy Savings 2,001,972 2,230,858 1,131,217$

Wattsmart Business - Commercial 2,099,123 2,333,028 730,246$ Wattsmart Business - Industrial 552,315 607,088 172,285$ Wattsmart Business - Irrigation 721,377 803,838 226,851$ Wattsmart Business total 3,372,815 3,743,954 1,129,382$

Portfolio 270,932$ Total Energy Efficiency 5,374,788 5,974,812 2,531,531$ 2020 Savings Target 5,250,000

Advice Letter No. 588-E September 3, 2019 Page 6 Tables 3 and 4 below show the 2020 expenditure forecast with a breakdown of expenses, including at minimum, the following categories: incentive payments, program evaluation, and administrative expenses.

Table 2 - 2020 Portfolio Level Forecast Expenditures - Breakdown by Cost Category

Table 3 - 2020 Program Level Forecast Expenditures - Breakdown by Cost Category

II. 2020 Projected Overall Portfolio Metrics

A. Capturing Energy Savings

First year annual and lifecycle ex-ante (pre-evaluation) electric and demand savings (gross and net) are identified in Tables 5–7 below.

2020 Forecast Expenditures % of Total

Administrative Costs $ 103,938 4%Incentive Payments $ 1,380,869 55%Direct Implementation - non-incentives $ 828,709 33%IOUs administered marketing, education and outreach $ 25,864 1%Program Evaluation $ 192,152 8%Total $ 2,531,531 100%

2020 Home Energy Savings Forecast

Expenditures (a)

2020 Wattsmart Business Forecast

Expenditures (b)

2020 Portfolio Forecast

Expenditures (c)

2020 Total Forecast

Expenditures(a+b+c)

% of Total

Administrative Costs $ 35,075 $ 44,833 $ 24,030 103,938$ 4%Incentive Payments $ 850,952 $ 529,917 $ - 1,380,869$ 55%Direct Implementation - non-incentives $ 245,000 $ 528,959 $ 54,750 828,709$ 33%IOUs administered marketing, education and outreach $ 191 $ 25,674 $ - 25,864$ 1%Program Evaluation $ - $ - $ 192,152 192,152$ 8%Total $ 1,131,217 $ 1,129,382 $ 270,932 2,531,531$ 100%


Table 4 – Projected 2020 First Year Annual Gross and Net kWh Savings7

Table 5 - Projected 2020 Lifecycle Gross and Net kWh Savings8

Table 6 - Projected 2020 Gross and Net kW Savings9

B. Disadvantaged Communities First year annual and lifecycle ex-ante (pre-evaluation) electric and demand savings (gross and net) in disadvantaged communities are not identified in this report as the company does not serve businesses or homes in disadvantaged communities, as identified by the California Environmental Protection Agency (CalEPA) pursuant to Health and Safety Code Section 39711.10 For reference, see the map of PacifiCorp’s service area in California and the disadvantaged communities map below.

7 Net savings include realization rates and NTG ratios. 8 Lifecycle savings is without discount rate. 9 Kilowatt (kW) savings is not additive over the measure life since it is time independent and therefore lifecycle impacts are reported consistent with first year kW savings. Totals may be off due to rounding. 10 https://www.energy.ca.gov/commission/diversity/definition.html

ProgramFirst Year Annual

Gross kWh Savings at Site

First Year Annual Net kWh Savings

at Site

First Year Annual Gross kWh Savings

at Generator


at Generator

Home Energy Savings 2,001,972 1,003,737 2,230,858 1,118,494Wattsmart Business 3,372,815 2,639,157 3,743,954 2,929,543Total 5,374,788 3,642,893 5,974,812 4,048,037

ProgramLifecycle


Lifecycle Net kWh Savings

at Site

Lifecycle Gross kWh Savings

at Generator


at Generator

Home Energy Savings 23,521,354 12,290,770 26,210,551 13,695,974Wattsmart Business 41,983,361 32,860,900 46,594,115 36,470,000Total 65,504,715 45,151,670 72,804,666 50,165,974

Gross kW Savings at Site

Net kW Savings at Site

Gross kW Savings at Generator

Net kW Savings at Generator

Home Energy Savings 349 175 389 195 Wattsmart Business 588 460 653 511 Total 937 635 1,042 706


Figure 1 - PacifiCorp Service Area in California


Figure 2 - Disadvantaged Communities Map (from CalEPA)11

11 https://calepa.ca.gov/wp-content/uploads/sites/6/2017/04/SB-535-Maps-Final.pdf


C. Hard-to-Reach Markets First year annual and lifecycle ex-ante (pre-evaluation) electric and demand savings (gross and net) in hard-to-reach markets are provided in Tables 8–10 below.

Projections for Hard-to-Reach participation in 2020 are estimated using limited data collected in 2019. Because there was not adequate data available to provide a projection for PacifiCorp’s Home Energy Savings program, to be conservative from a cost-effectiveness analysis perspective, no Hard-to-Reach participation is in included in the company’s forecast.

Attachment 2 of this filing provides descriptions by program for how PacifiCorp is currently collecting data to identify Hard-to-Reach participants.

Table 7 - Hard-to-Reach Markets – Projected 2020 First Year Annual Gross and Net kWh Savings

Table 8 - Hard-to-Reach Markets - Projected 2020 Lifecycle Gross and Net kWh Savings

Table 9 - Hard-to-Reach Markets - Projected 2020 Gross and Net kW Savings

D. Cost Per Unit Saved

The levelized cost of energy efficiency per kWh and kW (both Total Resource Cost and Program Administrator Cost) are provided in Table 11.

ProgramFirst Year Annual



at Site

First Year Annual Gross kWh Savings

at Generator


at GeneratorHome Energy Savings 0 0 0 0Wattsmart Business 443,427 364,512 493,291 405,515Total 443,427 364,512 493,291 405,515

ProgramLifecycle



at Site

Lifecycle Gross kWh Savings

at Generator


at Generator

Home Energy Savings 0 0 0 0Wattsmart Business 5,215,663 4,272,105 5,801,155 4,751,810Total 5,215,663 4,272,105 5,801,155 4,751,810

Gross kW Savings at Site

Net kW Savings at Site

Gross kW Savings at Generator

Net kW Savings at Generator

Home Energy Savings 0 0 0 0Wattsmart Business 77 64 86 71 Total 77 64 86 71


Table 10 - 2020 Forecast Cost per Unit Saved

III. 2020 Projected Cost Effectiveness The portfolio, including the planned changes for 2020, is projected to exceed 1.0 for both the Total Resource Cost (TRC) and Program Administrator Cost (PAC) perspectives using PacifiCorp’s cost-effectiveness model. Results of the model are shown in Table 12 below. Attachment 3 provides additional cost-effectiveness results from multiple perspectives for 2020 as well as the 2018–2020 period.

Table 11 - 2020 Projected Cost Effectiveness12

A. Net-to-Gross Ratios

The company used approved net-to-gross ratios from the Database for Energy Efficient Resources (DEER) as of August 1, 2019 in the cost-effectiveness assessment for the 2019 and 2020 forecast program years. Attachment 4 shows the DEER net-to-gross values by program and measure or by measure group.

B. PacifiCorp Model Decision 18-11-033 provided the following guidance to PacifiCorp regarding using its own cost-effectiveness model through 2020. “PacifiCorp may use its company-specific avoided cost calculator through 2020 provided that, in calculating its cost-effectiveness metrics (e.g., the TRC and PAC), PacifiCorp comply with applicable directives specified in this decision, including the 10 percent cap on administrative expenses and utilization of correct DEER values, and in other relevant Commission proceedings, primarily the total resource value framework (R.14-10-003), 12 As discussed with Staff on August 22, 2019, the current measure life in DEER for the residential duct sealing measure is three years, which is acknowledged to be in error (too short). The prior value was 18 years. Absent a corrected value, PacifiCorp used 3 years for 2019 and 7 years for 2020 in the cost-effectiveness analysis. Seven years was chosen since it is approximately half of the life of the mechanical heating/cooling equipment.

Cost-Effectiveness TestLevelized

$/kWhLevelized

$/kWTotal Resource Cost Test (TRC) No Adder $0.1013 $581.11Program Administrator Cost (PAC) $0.0745 $426.95

Program

2020 Forecast TRC benefit

cost ratio

2020 Forecast PAC benefit

cost ratioHome Energy Savings 0.66 0.92 Wattsmart Business 1.74 2.46 Total Portfolio 1.11 1.51

Advice Letter No. 588-E September 3, 2019 Page 12 that will have a major impact on cost-benefit assessments. In short, allowing PacifiCorp to use its avoided cost calculator does not undo the requirements laid out in Ordering Paragraph 3 of D.14-04-088 or in Ordering Paragraph 6 of this decision. PacifiCorp should document appropriate adjustments to its avoided cost calculator in a separate report or manual, to ensure continued alignment with related Commission decisions.” The Company evaluates program implementation cost-effectiveness (both prospectively and retrospectively) under a variety of tests to identify the relative impact and/or value (e.g., near-term rate impact, program value to participants, etc.) to customers and the company. Program cost effectiveness is evaluated using a company-specific modeling tool, created by a third party consultant. Based on Decision 18-11-033, PacifiCorp’s model13 was revised in 2018 to include a greenhouse gas adder for the incremental value of avoided greenhouse gas emissions. The tool is designed to incorporate PacifiCorp data and values such as avoided costs,14 and generally follows the methodology specified in California’s Standard Practice Manual. PacifiCorp’s modeling tool conducts cost effectiveness analysis on all four tests described in the Standard Practice Manual15 as well as an additional fifth test.16 The company’s analysis assesses the costs and benefits of demand-side management programs from different stakeholder perspectives, including participants and non-participants. PacifiCorp’s consultant Navigant recently reviewed the California Energy Data and Reporting System (CEDARS) to identify any updates that would need to be made in PacifiCorp’s model for use for this ABAL and no updates were identified. Attachment 5 of this filing contains a comprehensive description of PacifiCorp’s cost-effectiveness tool.

IV. 2020 Program Changes PacifiCorp’s Home Energy Savings and Wattsmart Business programs were updated in 2019 using the approved program change process, with these changes effective August 26, 2019. Below is a brief description of each program and a summary of planned changes for 2020 for each of PacifiCorp’s energy efficiency programs17.

13 In 2017, the company transitioned from California’s E3 Calculator to the PacifiCorp cost effectiveness model. The change in models was a coordinated effort between the company, Staff and its third party consultant, Itron. Additional information regarding PacifiCorp’s transition to its company specific cost effectiveness model can be found in Application No. 17-09-010. 14 Avoided costs in the model are from the company’s 2017 Integrated Resource Plan. The 2019 Integrate Resource Plan is expected to be available in October 2019. 15 Total Resource Cost test (“TRC”), Program Administrator Cost test (“PAC”), Ratepayer Impact (“RIM”), and Participant Cost Test (“PCT”). 16 PacifiCorp TRC (“PTRC”), total resource cost test with an additional 10% added for the non-quantified environmental and non-energy benefits. 17 The Home Energy Savings and Wattsmart Business programs are ongoing and PacifiCorp anticipates making commitments under the current programs in 2020 for projects that may not be completed until after December 31, 2020.


A. Program Description Home Energy Savings (Schedule D-118) The Home Energy Savings program uses the company’s Wattsmart brand for outreach. The program is designed to provide access to and incentives for more efficient products and services installed or received by customers in new or existing homes, multi-family housing units or manufactured homes. Turnkey delivery of Home Energy Savings is outsourced, and as of April 2019, the new provider is Nexant, Inc. The August 26, 2019 changes for this program were designed to incorporate modifications necessary to administer the program through 2020. In the event additional changes are identified, they will be made using the program change process contained in Schedule D-118 and provided at the end of this section. Wattsmart Business (Schedule A-140) The commercial, industrial and irrigation energy efficiency program is consolidated into a single Non-Residential Energy Efficiency program, Schedule A-140.18 The Non-Residential Energy Efficiency program is promoted to the company’s customers as Wattsmart Business. Wattsmart Business is intended to maximize the efficient use of electricity for new and existing non-residential loads through the installation of energy efficiency measures and energy management protocols. Qualifying measures are measures which, when implemented in an eligible facility, result in verifiable electric energy efficiency improvements. Services and incentives offered through Wattsmart Business include:

Typical Upgrades: Incentives for lighting, HVAC, irrigation, compressed air and other equipment upgrades that increase electrical energy efficiency and exceed energy code requirements.

Custom Analysis: Energy analysis studies, services and incentives for more complex projects.

Energy Management: Expert facility and process analysis and incentives to help lower energy costs by optimizing a customer’s energy use.

18 Program details such as incentive tables and program definitions are available on our website at https://www.pacificpower.net/content/dam/pcorp/documents/en/pacificpower/savings-energy-choices/wattsmart-business/california/CA_wattsmartBusiness_Definitions_Incentive_Tables_Information.pdf The program overview is available at https://www.pacificpower.net/content/dam/pcorp/documents/en/pacificpower/savings-energy-choices/wattsmart-business/california/CA_Overview.pdf The program brochure is available at https://www.pacificpower.net/content/dam/pcorp/documents/en/pacificpower/savings-energy-choices/wattsmart-business/california/CA_wattsmartBusiness_Brochure.pdf


Enhanced Incentives for Small Businesses: Provides enhanced incentives for lighting upgrades installed by an approved Wattsmart Small Business Contractor at an eligible existing small business customer facility.

Midstream/Lighting Instant Incentive: Instant, point-of-purchase incentives for qualifying lamps sold through participating distributors. Customers who purchased lamps from non-participating suppliers can apply for incentives after purchase.

Energy Project Manager Co-funding: Available to customers who commit to an annual goal of completing energy projects resulting in at least 1,000,000 kWh/year in energy savings.

Project Financing: PacifiCorp has teamed with National Energy Improvement Fund (NEIF),19 an energy efficiency project financing firm, to provide customers with access to third party financing options for instances where funds for project implementation are not available from within the customer’s organization.

Wattsmart Business delivery is currently outsourced to Nexant, Inc. and Cascade Energy.20 PacifiCorp communications staff maintains the program website and other marketing functions such as advertising and program collateral.

B. Summary of Program Changes for 2020:

The program was substantially updated with the program changes that went into effect August 26, 2019. A few additional changes have been identified for 2020, and these changes are intended to update the program to:

align with DEER updates since the last program change align with updates to third-party specifications such as Consortium for Energy Efficiency align with updates to Regional Technical Forum analysis for the irrigation hardware

measures add a new ductless heat pump measure make other minor changes

Program measures were also reviewed to identify updates needed to align with the state energy code effective 1/1/2020 (2019 Building Energy Efficiency Standards).

C. Program Change Process:

PacifiCorp will use the approved program change process for 2020 program changes. The approved program change processes for the Home Energy Savings and Wattsmart Business programs are similar. Below is background by program. This background was referenced in PacifiCorp’s Application for 2018-2020 (A 13-07-015) filed September 15, 2017.

19 Information on financing is available at https://www.pacificpower.net/savings-energy-choices/business/project-

financing.html 20 Nexant, Inc. and Cascade Energy were selected as part of two Request for Proposals for program delivery services. The new contracts began in 2019.


Home Energy Savings – Appendix J from Application 07-07-011 filed July 16, 2007 described the program change process for Home Energy Savings. The relevant text from page 2 of Appendix J is copied below:

“The comprehensive nature of the Program and changing equipment standards indicate that a flexible and market-driven program delivery is required. PacifiCorp is proposing that Schedule D-118 outline the basic program elements, including: customer eligibility, use of a program administrator for delivery, the seasonal nature of selected incentive offers, and that current incentive levels may change. Specific details on all aspects of the program including incentive levels, eligible equipment specifications and dates for incentive availability would be managed by the program administrator using a dedicated program web site with easy links from the Pacific Power web site. Changes in equipment specifications or incentive levels would be clearly posted on the Web site with at least 45 days advance notice.”

Wattsmart Business – Exhibit E – Program Change Process from Advice Letter 518-E filed February 24, 2015 (See Attachment 6)

V. Verification of Prior Year Savings (2018) PacifiCorp issued its annual report for 2018 on March 15, 2019.21 Tables 13 and 14 below show the overall results from this report.

Table 12 - 2018 Overall Portfolio Level Metrics

2018 Total Portfolio PerformanceInvestment $1,914,794

kWh-first year Savings (gross at generation) 5,568,457 kWh-first year Savings (net at generation) 3,278,604

kW of capacity reduction (gross at generation) 971 kW of capacity reduction (net at generation) 572

Portfolio Total Resource Cost (TRC) – PacifiCorp Model with greenhouse gas adder

1.34

21 http://www.pacificorp.com/content/dam/pacificorp/doc/Energy_Sources/Demand_Side_Management/2018/2018_CA_DSM_Annual_Report_Final.pdf


Table 13 - 2018 Ex-Ante Savings and Expenditures

A. Evaluations and Verification Evaluations are performed by independent external evaluators to validate energy and demand savings derived from the company’s energy efficiency programs. The company adopts industry best practices with regards to principles of operation, methodologies, evaluation methods, definitions of terms, and protocols including those outlined in the National Action Plan for Energy Efficiency Program Impact Evaluation and the California Evaluation Framework guides. A component of the overall evaluation efforts is aimed at the reasonable verification of installations of energy efficient measures and associated documentation through review of documentation, surveys and/or ongoing onsite inspections.

The company engages in programmatic verification activities, including inspections, quality assurance reviews, and tracking checks and balances as part of routine program implementation and may rely upon these practices in the verification of installation information for the purposes of savings verifications in advance of more formal impact evaluation results. A summary of the

kWh Savings (Gross at site)

kWh Savings (Gross at

generator)Investment

Home Energy Savings 1,128,461 1,257,478 $ 602,654

Total Residential 1,128,461 1,257,478 $ 602,654

WSB Commercial 2,058,178 2,287,521 $ 556,291 WSB Industrial 1,038,314 1,141,284 $ 322,678 WSB Irrigation 791,678 882,175 $ 213,960 TOTAL WSB 3,888,170 4,310,979 $ 1,092,929

Portfolio - EM&V $ 212,316 Portfolio - DSM Central $ 3,980

Portfolio - TRL $ 2,915

Total Energy Efficiency 5,016,631 5,568,457 $ 1,914,794

Advice Letter No. 588-E September 3, 2019 Page 17 inspection process is included in Appendix 1 of the company’s 2018 California Annual Review of Energy Efficiency Programs.22

Evaluation, measurement and verification tasks are segregated within the company to ensure they are performed and managed by personnel who are not directly responsible for program management. Table 15 below shows the status of evaluations by program.23

Table 14 - Status of Program Evaluations

Program Years

Evaluated Evaluator Progress Status Home Energy Savings 2017 – 2018 ADM In progress Home Energy Savings 2015 – 2016 Cadmus Final Report – Dec. 6, 2017

Wattsmart Business 2018 – 2019 TBD RFP underway Wattsmart Business 2016 – 2017 Cadmus Final Report – Oct. 25, 2018

VI. Breakdown of 2019 Year-to-Date Expenditures as of June 30, 2019 PacifiCorp provides the detail of 2019 year-to-date24 expenses in this section, allowing Staff to see the percentage associated with incentive payments, program evaluation and administrative expenses. PacifiCorp met with Staff in February 2019 to review Overall Portfolio Metrics reporting. As a follow-up, the company provided its cost category reporting descriptions to Staff on May 24, 2019. These descriptions were used to prepare the breakdown of 2019 YTD expenditures. The descriptions provided on May 24, 2019 are available in Attachment 1.

22 2018 California Annual Review of Energy Efficiency Report available at https://www.pacificorp.com/content/dam/pcorp/documents/en/pacificorp/environment/dsm/california/2018_CA_DSM_Annual_Report_Final.pdf 23 Completed evaluation reports are available at https://www.pacificorp.com/environment/demand-side-management.html. 24 Year-to-date expenses include estimates for outsourced delivery work completed in the January-June 2019 period but not invoiced as of June 30, 2019.


Table 15 – 2019 YTD Portfolio Level Expenditures - Breakdown by Cost Category

Table 16 - 2019 YTD Program Level Expenditures – Breakdown by Cost Category

VII. 2018-2020 Budget and Savings Compared to PacifiCorp’s Application Approved in Decision 18-11-033

PacifiCorp is managing expenditures to the three-year 2018-2020 budget and savings target in its 2018-2020 Application. Tables 18 and 19 below show the three-year portfolio expenditures are forecast to be 3% above the budget in the Application and portfolio savings is forecast to be approximately 113% of the target in the Application.

2019 Year-to-Date Expenditures

as of June 30, 2019 % of TotalAdministrative Costs $ 85,908 7%Incentive Payments $ 335,680 29%Direct Implementation - non-incentives $ 675,342 59%IOUs administered marketing, education and outreach $ 10,862 1%Program Evaluation $ 43,641 4%Portfolio Total $ 1,151,433 100%

2019 YTD Home Energy

Savings Expenditures

as of 6/30/2019(a)

2019 YTD Wattsmart Business

Expendituresas of 6/30/2019

(b)

2019 YTD Portfolio

Expendituresas of 6/30/2019

(c)

2019 YTD Total Expenditures

as of 6/30/2019(a+b+c)

% of Total

Administrative Costs $ 18,704 $ 22,145 $ 45,058 85,908$ 7%Incentive Payments $ 122,901 $ 212,779 $ - 335,680$ 29%Direct Implementation - non-incentives $ 308,029 $ 362,393 $ 4,920 675,342$ 59%IOUs administered marketing, education and outreach $ - $ 10,862 $ - 10,862$ 1%Program Evaluation $ - $ - $ 43,641 43,641$ 4%Total $ 449,634 $ 608,179 $ 93,619 1,151,433$ 100%


Table 17 - 2018-2020 Budget Compared to PacifiCorp’s Application

Table 18 - 2018-2020 Savings Compared to PacifiCorp’s Application (Gross MWH at generator)

Application 2018 2019 2020 2018-2020

Home Energy Savings 647,169$ 642,459$ 727,809$ 2,017,437$ Wattsmart Business 1,267,239$ 1,333,343$ 1,385,711$ 3,986,293$ Evaluation 184,200$ 109,650$ 189,924$ 483,774$ Utility Administration 123,433$ 122,424$ 123,910$ 369,767$ Total 2,222,041$ 2,207,876$ 2,427,354$ 6,857,271$ 2020 Annual Budget Advice Letter

2018 (as reported) 2019 Forecast 2020 Forecast

2018-2020 Forecast

Home Energy Savings 602,654$ 762,301$ 1,131,217$ 2,496,172$ Wattsmart Business 1,092,929$ 1,598,178$ 1,129,382$ 3,820,488$ Evaluation 212,316$ 73,502$ 192,152$ 477,970$ Portfolio 6,896$ 152,502$ 78,780$ 238,178$ Total 1,914,794$ 2,586,482$ 2,531,531$ 7,032,807$ Total % of Application 86% 117% 104% 103%

Application2018 2019 2020 2018-2020

Home Energy Savings 1,355 1,475 1,655 4,485 Wattsmart Business 4,964 5,258 5,502 15,724 Total Portfolio 6,319 6,733 7,157 20,209 Target 7,340 5,130 5,250 17,720 Portfolio - target (1,021) 1,603 1,907 2,489

2020 Annual Budget Advice Letter2018

(as reported) 2019 Forecast 2020 Forecast2018-2020 Forecast

Home Energy Savings 1,257 1,073 2,231 4,561 Wattsmart Business 4,311 7,485 3,744 15,540 Total 5,568 8,558 5,975 20,101 Target 7,340 5,130 5,250 17,720 Total - target (1,772) 3,428 725 2,381 % of Total in Application 88% 127% 83% 99%% of Target in Application 76% 167% 114% 113%

Advice Letter No. 588-E September 3, 2019 Page 20 PROTEST Anyone wishing to protest this filing may do so by letter sent via U.S. mail, by facsimile or electronically, any of which must be received no later than September 24, 2019.

Energy Division Tariff Unit, 4th Floor 505 Van Ness Avenue San Francisco, CA 94102 Email: [email protected]

Copies of protests should also be mailed to the attention of the Director, Energy Division, Room 4004, at the address shown above. Additionally, the protest should be sent via U.S. mail (and electronically, if possible) to PacifiCorp at the address shown below on the same date it is mailed or delivered to the Commission. Pooja Kishore

Regulatory Affairs Manager PacifiCorp 825 NE Multnomah, Suite 2000 Portland, OR 97232 Telephone: (503) 813-7314 E-mail: [email protected]

With a copy to: Carla Scarsella Senior Regulatory Attorney

PacifiCorp 825 NE Multnomah, Suite 2000 Portland, OR 97232 Telephone: (503) 813-6338 E-mail: [email protected]

There are no restrictions on who may file a protest, but the protest must set forth specifically the grounds upon which it is based and be submitted expeditiously. EFFECTIVE DATE In accordance with the Decision, ordering paragraph 5, this advice letter filing is submitted as a Tier 2 filing. PacifiCorp requests that this advice filing become effective no later than January 1, 2020, which is more than 30 days after the date of this filing. NOTICE In accordance with General Order 96-B, Section 4, a copy of this Advice Letter will be served electronically or via U.S. mail to parties shown on the GO 96-B service list and on the service list for A.17-09-010, copies of which are attached. A request for change of address in the

Advice Letter No. 588-E September 3, 2019 Page 21 GO 96-B service list should be directed by electronic mail to [email protected]. Advice letter filings may also be accessed electronically at www.pacificpower.net/regulation. PacifiCorp respectfully requests that all data requests regarding this matter be addressed to (with a copy to the Company’s counsel): By email (preferred): [email protected] By regular mail: Data Request Response Center PacifiCorp 825 NE Multnomah, Suite 2000 Portland, OR 97232 Please direct any informal questions to Pooja Kishore, Regulatory Affairs Manager, at (503) 813-7314. Sincerely, Etta Lockey Vice President, Regulation Enclosures

Attachment 1

PacifiCorp’s Cost Category Reporting Descriptions

Attachment 1 – PacifiCorp Cost Category Reporting Descriptions

1) Administrative costs

a) Fully loaded labor costs for Company staff associated with California demand-side management programs

i) Includes costs for internal Company staff labor (e.g. program managers and staff supporting EM&V, reporting, direct implementation)

ii) Includes employee expenses associated with programs

iii) Includes in-house contractor labor and expenses

iv) Includes membership dues associated with programs (ESource, IES, etc.)

2) Incentive Payments (Direct implementation-incentives and rebates)

a) Customer incentives

b) Partner incentives

c) Home Energy Savings - kits

3) Direct implementation non-incentives

a) Outsourced program delivery costs

b) Energy engineering services provided for business customer projects

c) Costs for program development work performed by third parties (including cost-effectiveness analysis, measure development)

d) Costs for systems and systems maintenance paid to third parties

4) IOUs administered marketing, education, and outreach

a) Outsourced ad agency costs (development of marketing materials, ad agency costs for media placements)

b) Costs for utility administered printing, direct mail, e-blasts

c) Internal Company staff labor responsible for marketing

d) Customer surveys – DSM Survey

e) Tools for customer access to understand their billing data

5) Program Evaluation (EM&V)

a) Outsourced program evaluation costs (consultant costs only)

b) Outsourced costs for cost-effectiveness analysis for evaluations, annual report (consultant costs only)

1

Attachment 2

Overall Portfolio Metrics – Hard-to-Reach Reporting Descriptions

Attachment 2 – Overall Portfolio Metrics – Hard-to-Reach Reporting Descriptions

The descriptions below for each program explain how PacifiCorp is currently collecting the data used to identify participants who meet the Hard-to-Reach criteria defined in Decision 18-05-041, pages 159-160 (copied at the end of this attachment).

All participants in both programs meet the geographic criteria (see Figure 1 above for a map of PacifiCorp’s service area in California).

Home Energy Savings

Data on hard-to-reach criteria is requested from all participants except those who purchase lamps at a bought down price from a participating retailer. Participant information is not collected for the lighting buy-down channel of Home Energy Savings.

Language – Primary language spoken is other than English

Data used to identify participants who meet this criteria is based on self-reported information from the participant contact on their incentive application1. They answer the question “Is customer’s primary language a language other than English?”

Income – Those customers who qualify for the California Alternative Rates for Energy (CARE)

Data used to identify participants who meet this criteria is based on self-reported information for the household from the participant contact on their incentive application. They answer the question “Is your household eligible for California Alternative Rates for Energy (CARE)?”

1 An example incentive application is available at https://wattsmartsavings.net/california-residential/savings-application/

1

Housing Type – Multi-family and Mobile Home Tenants (rent and lease)

Data used to identify participants who meet this criteria is based on self-reported information from the participant contact on their incentive application. Participants provide their home type (single-family, multi-family or manufactured home) and answer this question – “Do you rent/lease the location where the product(s) were installed?”

Wattsmart Business

Data on hard-to-reach criteria is requested for all participants except Instant Incentive (mid-market) lighting and green motor rewind participants who receive their incentive as a credit at the point of purchase.

Language – Primary language spoken is other than English

Data used to identify participants who meet this criteria is based on self-reported information from the participant contact on their incentive application2. They answer the question “Contact primary language spoken is language other than English?” for themselves as the participant contact (not for the business overall).

2 An example Wattsmart Business incentive application is available at https://www.pacificpower.net/content/dam/pcorp/documents/en/pacificpower/savings-energy-choices/wattsmart-business/california/CA_wattsmartBusiness_General_Application_with_address.pdf

2

Business size – Less than ten employees and/or classified as Very Small – Customers whose annual electric demand is less than 20 kilowatt (kW)

Data used to identify participants who meet this criteria is based on the rate schedule code for the electric account associated with the project. PacifiCorp may collect information on number of employees in the future.

Examples of rate codes for accounts less than 20KW:

06GNSV0025 – CALIFORNIA GENERAL SERVICE (LESS THAN 20 KW) 06GNSV025F – CALIFORNIA GENERAL SERVICE, FLAT RATE (LESS THAN 20

KW) 06NMT25135 – CA NET METERING GENERAL SERVICE LESS THAN 20 KW 06RGNSV025 – RESIDENTIAL USE, SMALL GENERAL SERVICE RATE (LESS

THAN 20 KW) 06APSV0020 – CALIFORNIA AGRICULTURAL PUMPING 06APSV0115 – CA AGRICULTURAL PUMPING TIME-OF-USE PILOT, GHG

CREDIT 06NMT20135 – CA AGRICULTURAL PUMPING – NET METER 06USBR0020 – CALIFORNIA USBR IRR CONTRACTS, ON PROJECT LAND 06USBR0115 – CA AGRICULTURAL PUMP TOU PILOT, USBR CUSTS, GHG CR

Leased or Rented Facilities – Investments in improvements to a facility rented or leased by a participating business customer

Data used to identify participants who meet this criteria is based on self-reported information from the participant on their incentive application. Participants answer this question for the project site – “Does Participant rent/lease the project site location?”

3

Reference Information copied from Decision 18-05-041, pages 159-160 - http://docs.cpuc.ca.gov/PublishedDocs/Published/G000/M215/K706/215706139.PDF For purposes of administering energy efficiency programs, hard-to-reach customers are defined pursuant to the criteria identified in Resolution G-3497, with one modification. Specifically:

Specific criteria were developed by Staff to be used in classifying a customer as hard-to-reach. Two criteria are considered sufficient if one of the criteria met is the geographic criteria defined below. There are common as well as separate criteria when defining hard-to-reach for residential versus small business customers. The barriers common to both include: o Those customers who do not have easy access to program information or generally do not participate in energy efficiency programs due to a combination of language, business size, geographic, and lease (split incentive) barriers. These barriers to consider include:

Language – Primary language spoken is other than English, and/or

Geographic – Businesses or homes in areas other than the United States Office of Management

and Budget Combined Statistical Areas of the San Francisco Bay Area, the Greater Los Angeles Area and the Greater Sacramento Area or the Office of Management and Budget metropolitan statistical areas of San Diego County.

Businesses or homes in disadvantaged communities, as identified by CalEPA pursuant to Health and Safety Code Section 39711.

o For small business added criteria to the above to consider:

Business Size – Less than ten employees and/or classified as Very Small (Customers whose annual electric demand is less than 20 kilowatts, or whose annual gas consumption is less than 10,000 therm, or both), and/or

Leased or Rented Facilities – Investments in improvements to a facility rented or leased by a participating business customer

o For residential added criteria to the above to consider:

Income – Those customers who qualify for the California Alternative Rates for Energy (CARE) or the Family Electric Rate Assistance Program (FERA), and/or

Housing Type – Multi-family and Mobile Home Tenants (rent and lease)

4

Attachment 3

Cost-Effectiveness Analysis

1375 Walnut Street

Suite 100 | Boulder, CO 80302

303.728.2500 main

navigant.com

Attachment 3 – Projected Cost-Effectiveness Results for the California Portfolio Level Results Program Years 2018-2020 Memo from Navigant Consultants

To: Nancy Goddard, PacifiCorp From: David Basak, Navigant Date: August 19, 2019 Re: Cost-Effectiveness Results for the California Portfolio Level Results

Program Years 2018-2020 Navigant estimated the cost-effectiveness for the overall energy efficiency portfolio and component sectors, based on 2018-2020 costs and savings estimates provided by PacifiCorp. This memo provides the cost-effectiveness results for the overall energy efficiency portfolio and the two sector components. The portfolio passes the cost-effectiveness for all cost tests except the RIM test in the combined PY2018-2020 overview. The memo consists of the following tables.

Table 1 – Portfolio Level Cost-Effectiveness Inputs Table 2 – Portfolio Level Annual Costs by Program Year Table 3 – Benefit/Cost Ratios – Portfolio Level PY2018-2020 Table 4 – Portfolio Level Cost-Effectiveness Results – PY2018-2020 Table 5 – C&I Portfolio Cost-Effectiveness Results – PY2018-2020 Table 6 – Residential Portfolio Cost-Effectiveness Results – PY2018-2020 Table 7 – Portfolio Level Cost-Effectiveness Results – PY2018 Table 8 – C&I Portfolio Cost-Effectiveness Results – PY2018 Table 9 – Residential Portfolio Cost-Effectiveness Results – PY2018 Table 10 – Portfolio Level Cost-Effectiveness Results – PY2019 Table 11 – C&I Portfolio Cost-Effectiveness Results – PY2019 Table 12 – Residential Portfolio Cost-Effectiveness Results – PY2019 Table 13 – Portfolio Level Cost-Effectiveness Results – PY2020 Table 14 – C&I Portfolio Cost-Effectiveness Results – PY2020 Table 15 – Residential Portfolio Cost-Effectiveness Results – PY2020

1

PY2018-2020 California Cost-Effectiveness Results – Portfolio Level August 19, 2019 Page 2 of 6

Table 1 – Portfolio Level Cost-Effectiveness Inputs

Parameter PY2018 PY2019 PY2020

Discount Rate 6.57% 6.57% 6.57%

Residential Line Loss 11.43% 11.43% 11.43%

Commercial Line Loss 11.14% 11.14% 11.14%

Industrial Line Loss 9.92% 9.92% 9.92%

Irrigation Line Loss 11.43% 11.43% 11.43%

Residential Energy Rate ($/kWh)¹ $0.1319 $0.1348 $0.1378

Commercial Energy Rate ($/kWh)¹ $0.1487 $0.1520 $0.1553

Industrial Energy Rate ($/kWh)¹ $0.1128 $0.1153 $0.1178

Irrigation Energy Rate ($/kWh)¹ $0.1497 $0.1530 $0.1564

Energy-to-Capacity Conversion Factor 0.000174387 0.000174387 0.000174387

Inflation Rate 2.20% 2.20% 2.20%

¹ Future rates determined using a 2.22% annual escalator.

Table 2 – Portfolio Level Annual Costs by Program Year

Expense PY2018 PY2019 PY2020 PY2018-PY2020

Portfolio - Administrative Costs $0 $83,826 $24,030 $107,856 Portfolio - Direct Implementation - non-incentives

$6,895 $68,676 $54,750 $130,321

Portfolio - IOUs administered marketing, education and outreach

$0 $0 $0 $0

Portfolio - Program Evaluation $212,316 $73,502 $192,152 $477,970

Total Costs $219,211 $226,004 $270,932 $716,147

Table 3 – Benefit/Cost Ratios – Portfolio Level PY2018-2020

Measure Group Program Year PTRC TRC PAC RIM PCT

Total Portfolio 2018 1.47 1.34 1.61 0.49 4.30

C&I Programs 2018 2.00 1.82 2.18 0.53 5.28

Residential Programs 2018 1.00 0.91 1.17 0.45 2.69

Total Portfolio 2019 1.65 1.50 2.33 0.55 3.43

C&I Programs 2019 2.14 1.95 3.51 0.59 3.91


Total Portfolio 2020 1.22 1.11 1.51 0.49 2.63

C&I Programs 2020 1.91 1.74 2.46 0.54 4.31


Total Portfolio 2018-2020 1.46 1.32 1.84 0.51 3.31

C&I Programs 2018-2020 2.05 1.86 2.82 0.56 4.33

Residential Programs 2018-2020 0.73 0.67 0.87 0.40 1.82

2


The following tables provide the cost-effectiveness results for the combination of program years 2018 through 2020 at the sector level.

Table 4 – Portfolio Level Cost-Effectiveness Results – PY2018-2020

Cost-Effectiveness Test Levelized

$/kWh Levelized

$/kW Costs Benefits

Net Benefits

Benefit/Cost Ratio

Total Resource Cost Test (PTRC) + Conservation Adder

$0.0822 $471.08 $9,763,800 $14,230,715 $4,466,915 1.46

Total Resource Cost Test (TRC) No Adder

$0.0822 $471.08 $9,763,800 $12,937,014 $3,173,213 1.32

Program Administrator Cost (PAC) $0.0592 $339.32 $7,032,807 $12,937,014 $5,904,207 1.84

Rate Impact Test (RIM) $25,185,174 $12,937,014 -$12,248,161 0.51

Participant Cost Test (PCT) $8,342,762 $27,630,775 $19,288,013 3.31

Lifecycle Revenue Impacts ($/kWh) $0.0000142632

Discounted Participant Payback (years)

2.83

Table 5 – C&I Portfolio Cost-Effectiveness Results – PY2018-2020


$/kWh Levelized

$/kW Costs Benefits

Net Benefits

Benefit/Cost Ratio


$0.0585 $335.46 $5,788,616 $11,844,135 $6,055,519 2.05


$0.0585 $335.46 $5,788,616 $10,767,396 $4,978,780 1.86






2.01

Table 6 – Residential Portfolio Cost-Effectiveness Results – PY2018-2020


$/kWh Levelized

$/kW Costs Benefits

Net Benefits

Benefit/Cost Ratio


$0.1638 $939.11 $3,259,037 $2,386,580 -$872,457 0.73


$0.1638 $939.11 $3,259,037 $2,169,618 -$1,089,419 0.67

Program Administrator Cost (PAC) $0.1254 $719.29 $2,496,172 $2,169,618 -$326,554 0.87





7.41

3


The following tables provide the cost-effectiveness results for program year 2018.

Table 7 – Portfolio Level Cost-Effectiveness Results – PY2018


$/kWh Levelized

$/kW Costs Benefits

Net Benefits

Benefit/Cost Ratio


$0.0783 $448.76 $2,306,238 $3,397,485 $1,091,247 1.47


$0.0783 $448.76 $2,306,238 $3,088,623 $782,385 1.34






2.80

Table 8 – C&I Portfolio Cost-Effectiveness Results – PY2018


$/kWh Levelized

$/kW Costs Benefits

Net Benefits

Benefit/Cost Ratio


$0.0580 $332.84 $1,312,134 $2,622,538 $1,310,405 2.00


$0.0580 $332.84 $1,312,134 $2,384,126 $1,071,992 1.82






2.06

Table 9 – Residential Portfolio Cost-Effectiveness Results – PY2018


$/kWh Levelized

$/kW Costs Benefits

Net Benefits

Benefit/Cost Ratio


$0.1129 $647.41 $774,893 $774,947 $54 1.00


$0.1129 $647.41 $774,893 $704,497 -$70,396 0.91

Program Administrator Cost (PAC) $0.0878 $503.51 $602,654 $704,497 $101,843 1.17

Rate Impact Test (RIM) $1,573,464 $704,497 -$868,967 0.45

Participant Cost Test (PCT) $689,382 $1,854,859 $1,165,476 2.69



5.65

4





$/kWh Levelized

$/kW Costs Benefits

Net Benefits

Benefit/Cost Ratio


$0.0724 $415.42 $4,012,012 $6,635,592 $2,623,580 1.65


$0.0724 $415.42 $4,012,012 $6,032,356 $2,020,345 1.50






2.39



$/kWh Levelized

$/kW Costs Benefits

Net Benefits

Benefit/Cost Ratio


$0.0558 $320.20 $2,875,865 $6,166,311 $3,290,447 2.14


$0.0558 $320.20 $2,875,865 $5,605,737 $2,729,873 1.95






2.07



$/kWh Levelized

$/kW Costs Benefits

Net Benefits

Benefit/Cost Ratio


$0.2347 $1,346.00 $910,143 $469,281 -$440,862 0.52


$0.2347 $1,346.00 $910,143 $426,619 -$483,524 0.47

Program Administrator Cost (PAC) $0.1966 $1,127.36 $762,301 $426,619 -$335,682 0.56

Rate Impact Test (RIM) $1,322,446 $426,619 -$895,827 0.32

Participant Cost Test (PCT) $730,927 $1,251,313 $520,386 1.71



6.27

5





$/kWh Levelized

$/kW Costs Benefits

Net Benefits

Benefit/Cost Ratio


$0.1013 $581.11 $3,445,550 $4,197,638 $752,087 1.22


$0.1013 $581.11 $3,445,550 $3,816,034 $370,484 1.11






3.58



$/kWh Levelized

$/kW Costs Benefits

Net Benefits

Benefit/Cost Ratio


$0.0644 $369.48 $1,600,618 $3,055,286 $1,454,668 1.91


$0.0644 $369.48 $1,600,618 $2,777,532 $1,176,915 1.74






1.85



$/kWh Levelized

$/kW Costs Benefits

Net Benefits

Benefit/Cost Ratio


$0.1718 $985.44 $1,574,001 $1,142,352 -$431,649 0.73


$0.1718 $985.44 $1,574,001 $1,038,502 -$535,499 0.66

Program Administrator Cost (PAC) $0.1235 $708.22 $1,131,217 $1,038,502 -$92,716 0.92





9.26

6

Attachment 4

Database of Energy Efficiency Resources (DEER) Net-to-Gross Values

Attachment 4 – Database of Energy Efficiency Resources (DEER) Net-to-Gross (NTG) Values

Home Energy Savings – 2020 – DEER NTG used in cost-effectiveness analysis (measure level, for measures with projected participation)

Measures Measure Category DEER NTG DEER NTG_ID

Energy Savings Kit ‐ Best ‐ 1 Bathroom ‐ CA Energy Kits ‐ DHW 0.55 Res‐Default>2

Energy Savings Kit ‐ Best ‐ 2 Bathrooms ‐ CA Energy Kits ‐ DHW 0.55 Res‐Default>2

Energy Savings Kit ‐ LED Only ‐ CA Energy Kits ‐ Lighting 0.91 Res‐InCmn‐Ltg‐LEDFixt

LED General Purpose: 60W Equivelant ‐ 100‐120 LPW ‐ Retail ‐ CA Lighting 0.91 Res‐InCmn‐Ltg‐LEDFixt



LED Specialty ‐ Can Retrofit: ≥ 10 to ≤ 12 Watts Lighting 0.91 Res‐InCmn‐Ltg‐LEDFixt

LED Specialty ‐ Can Retrofit: ˂10 Wa s Lighting 0.91 Res‐InCmn‐Ltg‐LEDFixt

LED Specialty ‐ BR‐R: 14 to ˂22 Wa s ‐ Retail ‐ CA Lighting 0.91 Res‐InCmn‐Ltg‐LEDFixt

LED Specialty ‐ Globe: ≥2 to ˂3 Wa s ‐ Retail ‐ CA Lighting 0.91 Res‐InCmn‐Ltg‐LEDFixt

LED Specialty ‐ Globe: ≥3 to ≤10 Watts ‐ Retail ‐ CA Lighting 0.91 Res‐InCmn‐Ltg‐LEDFixt

LED Specialty ‐ Candelabra: ≥3 to ≤5 Watts ‐ Retail ‐ CA Lighting 0.91 Res‐InCmn‐Ltg‐LEDFixt

LED Fixture ‐ ENERGY STAR ‐ CA Lighting 0.91 Res‐InCmn‐Ltg‐LEDFixt

New Homes ‐ Ductless Heat Pump ‐ CA CZ16 New Homes 0.55 Res‐Default>2

New Homes Whole Home Performance Path ‐ 15 to 29.99% Better than Code ‐ CA Whole Home 0.55 Res‐Default>2

Heat Pump Conversion ‐ Convert FAF w/CAC to Federal Standard ASHP ‐ CZ01 ‐ CA HVAC 0.55 Res‐Default>2

Heat Pump Conversion ‐ Convert FAF w/CAC to Federal Standard ASHP ‐ CZ16 ‐ CA HVAC 0.55 Res‐Default>2

Heat Pump Conversion ‐ Convert FAF w/out CAC to Federal Standard ASHP ‐ CZ01

‐ CA HVAC 0.55 Res‐Default>2

Heat Pump Conversion ‐ Convert FAF w/out CAC to Federal Standard ASHP ‐ CZ16

‐ CA HVAC 0.55 Res‐Default>2

Heat Pump Conversion ‐ Convert FAF w/CAC to 9.0 HSPF ASHP ‐ CZ01 ‐ CA HVAC 0.55 Res‐Default>2

Heat Pump Conversion ‐ Convert FAF w/CAC to 9.0 HSPF ASHP ‐ CZ16 ‐ CA HVAC 0.55 Res‐Default>2

Heat Pump Conversion ‐ Convert FAF w/out CAC to 9.0 HSPF ASHP ‐ CZ01 ‐ CA HVAC 0.55 Res‐Default>2

Heat Pump Conversion ‐ Convert FAF w/out CAC to 9.0 HSPF ASHP ‐ CZ16 ‐ CA HVAC 0.55 Res‐Default>2

Heat Pump Upgrade ‐ 9.0 HSPF ‐ 16 SEER ‐ CZ16 ‐ CA HVAC 0.6 Res‐sAll‐mHVAC‐Pkg‐dn



Single Family ‐ Ductless Heat Pump 9.0 HSPF Zonal ER ‐ CZ01 ‐ CA HVAC 0.55 Res‐Default>2

Single Family ‐ Ductless Heat Pump 9.0 HSPF Zonal ER ‐ CZ16 ‐ CA HVAC 0.55 Res‐Default>2

Single Family ‐ Ductless Heat Pump 9.0 HSPF eFAF ‐ CZ01 ‐ CA HVAC 0.55 Res‐Default>2

Manufactured Home ‐ Ductless Heat Pump 9.0 HSPF eFAF ‐ CZ01 ‐ CA Manufactured Homes 0.55 Res‐Default>2

Manufactured Home ‐ Duct Sealing ‐ Direct Install ‐ 34‐25% to ≤15% Total Leakage ‐

CZ01 ‐ CA HVAC 0.55 Res‐Default>2

Manufactured Home ‐ Duct Sealing ‐ Direct Install ‐ 34‐25% to ≤15% Total Leakage ‐


Manufactured Home ‐ Duct Sealing ‐ Direct Install ‐ ≥35% to ≤15% Total Leakage ‐


Manufactured Home ‐ Duct Sealing ‐ Direct Install ‐ ≥35% to ≤15% Total Leakage ‐


Room Air Conditioner ‐ ENERGY STAR ‐ CA HVAC 0.36 Res‐sAll‐mHVAC‐RCA

Heat Pump Water Heater 0‐55 Gallon ‐ 3.24 EF ‐ 50 Gallon replacing 40 Gallon ‐

CZ01 ‐ CA Water Heating 0.55 Res‐Default>2

Heat Pump Water Heater > 55 Gallon ‐ 3.5 EF ‐ 80 Gallon replacing 75 Gallon ‐ CZ16 ‐

CA Water Heating 0.55 Res‐Default>2

1

Wattsmart Business – 2020 DEER NTG used in cost-effectiveness analysis (measure group level)

Channel Measure GroupNTG_ID Version StartDate ExpiryDateNTG_Elec

Cascade Energy ‐ Trade

ally/project facilitation

Irrigation ‐ water distribution

equipment, sprinklers Agric‐Sprklr‐All DEER2019 1/1/2019 0 0.5




equipment, sprinklers ‐ HTR Agricult‐Default‐HTR‐di DEER2014 1/1/2013 0 0.85




equipment, all other except

sprinklers Agric‐Default>2yrs DEER2019 1/1/2019 0 0.6




equipment, all other except

sprinklers ‐ HTR Agricult‐Default‐HTR‐di DEER2014 1/1/2013 0 0.85



Irrigation ‐ irrigation pumps,

custom NonRes‐sAg‐mCust‐ci DEER2019 1/1/2019 0 0.7



Irrigation ‐ irrigation pumps,

custom ‐ HTR Agricult‐Default‐HTR‐di DEER2014 1/1/2013 0 0.85



Irrigation ‐ Energy

Management Agric‐Default>2yrs DEER2019 1/1/2019 0 0.6


ally/project facilitation Compressed air Ind‐Default>2yrs DEER2019 1/1/2019 0 0.6


ally/project facilitation Farm & Dairy Agric‐Default>2yrs DEER2019 1/1/2019 0 0.6


ally/project facilitation Refrigeration Com‐Default>2yrs DEER2019 1/1/2019 0 0.6

Small Business Lighting NonRes‐In‐Ltg‐LEDFixt DEER2019 1/1/2019 0 0.91

Small Business Lighting ‐ HTR Com‐Default‐HTR‐di DEER2014 1/1/2013 0 0.85

Nexant ‐ Midstream Midstream Lighting NonRes‐In‐Ltg‐LEDFixt DEER2019 1/1/2019 0 0.91

Nexant Trade Ally Building Shell Com‐Default>2yrs DEER2019 1/1/2019 0 0.6

Nexant Trade Ally Food Service Equipment Com‐Default>2yrs DEER2019 1/1/2019 0 0.6

Nexant Trade Ally HVAC NonRes‐sAll‐mHVAC‐Pkg DEER2019 1/1/2019 0 0.6

Nexant Trade Ally Lighting ‐ commercial NonRes‐In‐Ltg‐LEDFixt DEER2019 1/1/2019 0 0.91

Nexant Trade Ally Lighting ‐ commercial ‐ HTR Com‐Default‐HTR‐di DEER2014 1/1/2013 0 0.85

Nexant Trade Ally Lighting ‐ industrial NonRes‐In‐Ltg‐LEDFixt DEER2019 1/1/2019 0 0.91

Nexant Trade Ally Motors Ind‐Default>2yrs DEER2019 1/1/2019 0 0.6

Project manager ‐

commercial Energy Management Com‐Default>2yrs DEER2019 1/1/2019 0 0.6

Project manager ‐

industrial Energy Management Ind‐Default>2yrs DEER2019 1/1/2019 0 0.6

Project manager ‐

irrigation Energy Management Agric‐Default>2yrs DEER2019 1/1/2019 0 0.6

Project manager ‐

commercial Custom commercial Com‐Default>2yrs DEER2019 1/1/2019 0 0.6

Project manager ‐

industrial Custom industrial Ind‐Default>2yrs DEER2019 1/1/2019 0 0.6

Project manager ‐

irrigation Custom irrigation Agric‐Default>2yrs DEER2019 1/1/2019 0 0.6

exante database tables: NTG2020

This file created on 8/1/2019 2:15:20 PM while connected to AmazonWS‐RDS as sptviewer.

Program/Database Description: READI v.2.5.1 (Current Ex Ante data) options: include Non‐DEER data; 1/1/2017 ‐ 1/1/2021

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Attachment 5

Description of PacifiCorp Cost-Effectiveness Modeling Tool

Attachment 5 – Description of PacifiCorp Cost-Effectiveness Modeling Tool Overview: PacifiCorp utilizes third parties to develop and maintain cost effectiveness modeling tools to assess the economic benefits of energy efficiency programs The model used in California is developed and maintained by Navigant. The model is Excel based and compares benefits and costs for all tests except the PCT on an hourly basis over the measure life. Calculations can be performed on a measure or program basis. Program results can be aggregated from individual measures. Multiple programs can be aggregated into a portfolio. The modeling tool calculates cost effectiveness from the following perspectives which align with the Standard Practice Manual:

Total Resource Cost (TRC) Program Administrator Cost (PAC) Ratepayer Impact (RIM) Participant Cost Test (PCT).

In addition, the tool calculates a variant of the TRC, referred to in PacifiCorp reporting as the PacifiCorp TRC (P-TRC). This test is the TRC with an additional 10% added benefit for the non-quantified environmental and non-energy benefits that may be generated by energy efficiency. Avoided Costs: The avoided costs specific to energy efficiency imported into this model are generated by the decrement study process which compares the cost of its Integrated Resource Plan (IRP) preferred portfolio (which includes energy efficiency) to an alternate portfolio containing no new energy efficiency. The energy efficiency decrement values are fully shaped to represent the 8,760 hourly values that exist within a calendar year. A more complete description of the process and the values generated in the last IRP can be found at: https://www.pacificorp.com/content/dam/pcorp/documents/en/pacificorp/environment/dsm/2019-draft-study-docs/PacifiCorp_Class2_DSM_Decrement_Study.pdf Carbon: The decrement values include the costs of assumed emissions compliance. However, the avoided costs do not include a greenhouse gas adder consistent with D.17-08-022, as the scope of that rulemaking proceeding did not involve PacifiCorp. Based on Decision 18-11-033, PacifiCorp’s California model was revised in 2018 to include a greenhouse gas adder for the incremental value of avoided greenhouse gas emissions.

Load shapes: The model utilizes load shapes specific to end uses and the sector in which they measures are installed to calculate the avoided costs for each hour of the year. The sum of the avoided costs in each hour of the year is multiplied by the annual savings value. The library of load shapes available for modeling is a combination of publicly available information (Northwest Power and Conservation Council) and selected building simulation modeling. The load shape library contains

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approximately 150 separate load shapes available for California modeling. The full library resides outside the model and Navigant pulls shapes in as necessary for modeling. Discount rate: Benefits and costs are discounted by the model back to the present year (or year of interest if different than current year) using a single established nominal discount rate for all perspectives (societal, utility, participant ) This discount rate is also used for levelizing calculations. The discount rate in this model is nominal and is the same as the discount rate used in the most recent IRP (2017). When a new IRP is filed, the most model will be updated to include the most recent discount rate. Line losses: The model adds line losses as a percentage to the customer site specific measure energy savings based on sectors (residential, commercial, industrial, and irrigation). The line losses include the impacts of both transmission and distribution level service. The sector value is based on a weighted average calculation performed by PacifiCorp’s regulation department. The weighted average calculation utilizes values from the 2009 PacifiCorp Electric Operations Loss Study performed by Management Applications Consulting, Inc. (MAC). The values were last updated in 2012. Retail rates: The model utilizes average retail energy rates by customer sector within a state to calculate the PCT and RIM results. Average retail rates are calculated by PacifiCorp’s regulation department on regular basis and when updated, the new values are provided to Navigant. Inflation rate: The model uses a single real inflation rate to escalate forecasts or values beyond the period for which they are available if it is necessary for modeling. The inflation rate is the same rate as used by the most recent IRP (2017). Sales forecasts (MWh): Sales forecasts for a 20 year period are an input to this model and used to calculate life cycle revenue impacts for the RIM test. The sales forecasts by state are periodically updated by PacifiCorp and provided to Navigant for their use in this model. Net-to-gross ratio (NTGR): NTGRs are provided by PacifiCorp as an input to this model, and consistent with CPUC direction are sourced from the latest DEER data base. Consistent with the Standard Practice Manual, NTGRs are applied to the customer costs in the TRC test and to the energy savings benefits in both the TRC and PAC tests. Realization rates: Realization rates are provided by PacifiCorp as an input to this model and are used to adjust the energy savings (kWh) used for all the calculations. This adjustment is in addition to the application of NTGRs. The source of realization rates is typically program impact evaluations performed for PacifiCorp by a third party. Realization rates may be available by measure group or specific measures.

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Measure/effective useful life: Measure lives are provided by PacifiCorp as an input to this model and are used to identify to stream of energy savings benefits delivered over time. Measure lives are utilized in calculating benefits over time and lifecycle impacts (kWh and $). For the residential program which utilizes third party data (DEER, etc.), the measure life source is consistent with the source for unit energy savings. For the business program with substantively fewer deemed measures drawn from third party sources, the source for measure life is the Nexant measure life review completed in 2017 for PacifiCorp. The source for measure life is DEER where DEER values were available. In the limited cases where a program adopts a revised baseline methodology that includes two measure baselines: one defined by pre-conditions for the remaining useful life of the existing system and the second defined by current practice, the program will report energy savings from the first baseline period and use an adjusted measure life to account for the savings reduction from baseline period 1 to period 2 such that the lifetime savings is correct. For this case, this adjusted measure life is what is used to assess cost effectiveness. Energy to capacity conversion factor: The model utilizes an energy to capacity conversion factor to estimate the estimated kW impact of the energy efficiency programs during PacifiCorp’s system peak period. The system peak is not state specific. The energy-to-capacity conversion factor is developed from energy efficiency selections in the latest IRP (2017) the energy efficiency resources acquired through the Company’s programs have the same average load profile as those energy efficiency resources selected in the 2017 IRP. The calculation, provided by PacifiCorp, is the same for all saved energy and is provided to Navigant for use in the model. Costs: Energy efficiency measure, program and portfolio costs are an input to the model and provided by PacifiCorp. Measure costs align with the baseline assumptions used to quantify savings; i.e., retrofit, new construction, etc. Measure level cost effectiveness does not include the impacts of program costs. Program costs are provided at a program level and are included as an additional cost that reduces energy savings benefits generated by the sum of all measures. Portfolio costs for systems and shared services are added to summation of program benefits. The model utilizes California specific cost categories3 for non-incentive costs. Outputs/results: The model generates results by measure, by program (multiple measures) and by portfolio (multiple programs). Results are available in an electronic format in the model. The model also has templates that generate results from multiple perspectives into a tabular format. Model results (and units) include:

Costs ($) Benefits ($) Net benefits ($)

3 Decision 18-11-033 included an order to provide a breakdown of year‐to‐date expenses, including at minimum the following categories: incentive payments, program evaluation, and administrative expenses.

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Benefit/cost ratio ($/$) Levelized cost ($/kWh) Levelized cost ($/kW) Life cycle revenue impacts ($/kWh) Discounted participant payback (years) First year gross and net savings (kWh) at site and at generation Lifecycle gross and net savings (kWh) at site and at generation Lifecycle gross and net savings (kWh) at site and at generation

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Attachment 6

PacifiCorp’s Program Change Process – wattsmart Business

Attachment 6 – PacifiCorp Program Change Process – Wattsmart Business Program Change Process from Advice Letter 518-E filed February 24, 2015

Exhibit E Pacific Power Flexible Tariff Format – Change Process - California

This process applies to specific program details managed outside of the program tariff such as: Incentive tables

Program definitions

General incentive information

Phase Pacific Power Commission Staff

Identify need for change

Incentive amount

Eligible equipment

Prepare program change proposal Program details with marked changes

Explanation for changes

Cost effectiveness analysis (if changes impact cost effectiveness)

Provide proposal, supporting documents and request comments

Provide program change proposal

Request comments from Commission staff

Define comment period

Review proposal, provide comments

Request a meeting/call to discuss the proposal (if needed)

Comment Period

Planning

Resolve comments

Incorporate comments as appropriate, prepare final program details and explanation for changes

Provide response to comments to Commission staff (If no comments or all comments have been resolved the Company will proceed with the proposed changes)

Comment resolution

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Post change notice on website

Post change notice on website including final program details with marked changes and explanation for changes

Communicate changes to Commission staff and others

Changes effective 45 days from posting date

Implement changes

Noticing Period

Receive final changes

Link to notice on the website

Final program details with changes marked and explanation for changes

Response to any comments

Effective date for changes

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CERTIFICATE OF SERVICE GO-96B Distribution List

I hereby certify that, pursuant to the Commission’s Rules of Practice and Procedure, I

have on this 3rd of September, 2019, at Portland, OR, provided via email or US mail, a true and correct copy of PacifiCorp’s Advice Letter 588-E to the following: Robert M. Pocta California Public Utilities Commission Energy Cost of Service & Natural Gas Room 4205 505 Van Ness Avenue San Francisco, CA 94102 [email protected]

Ralph Cavanagh National Resources Defense Council 111 Sutter St. 20th Floor San Francisco, CA 94104

Edward Randolph Director Energy Division California Public Utilities Commission 505 Van Ness Avenue San Francisco, CA 94102

Jeanne B. Armstrong Goodin, MacBride, Squeri, Day & Lamprey 505 Sansome Street, Suite 900 San Francisco, CA 94111 [email protected]

James Wuehler California Public Utilities Commission [email protected]

Robert Finkelstein TURN [email protected]

Michael B. Day Goodin, MacBride, Squeri, Day & Lamprey 505 Sansome Street, Suite 900 San Francisco, CA 94111 [email protected]

Dan Marsh Liberty Utilities Manager, Rates and Regulatory Affairs 701 National Ave Tahoe Vista, CA 96148 [email protected]

Surprise Valley Electrification 516 US Highway 395 E Alturas, CA 96101-4228

________________________________ Katie Savarin Coordinator, Regulatory Operations

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BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF CALIFORNIA

Application of PACIFICORP (U-901-E), an Oregon Company, to Continue its Energy Efficiency Programs and the Surcharge to Fund Public Purpose Programs

Application No. 17-09-010 (Filed September 15, 2017)

CERTIFICATE OF SERVICE

I hereby certify that I have this day served a copy of PacifiCorp’s (U 901-E) Advice Letter No. 588-E Annual Budget Advice Letter for 2020 Energy Efficiency Programs on all known parties to A.17-09-010 by transmitting an e-mail message with the document attached to the individuals named in the official service list, last changed December 3, 2018. Executed on September 3, 2019, at Portland, Oregon.

____________________________________ Katie Savarin Coordinator, Regulatory Operations

CPUC Home

CALIFORNIA PUBLIC UTILITIES COMMISSIONService Lists

PROCEEDING: A1709010 - PACIFICORP - TO CONT FILER: PACIFICORP LIST NAME: LIST LAST CHANGED: DECEMBER 3, 2018

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Parties

AJAY KUMAR ATTORNEY PACIFICORP 825 NE MULTMOMAH STREET, STE. 1800 PORTLAND, OR 97232 FOR: PACIFICORP

Information Only

SARAH LERHAUPT MEGAN SOMOGYI CALIF PUBLIC UTILITIES COMMISSION ATTORNEY ENERGY EFFICIENCY BRANCH GOODIN, MACBRIDE, SQUERI, & DAY, LLP AREA 505 SANSOME ST., STE. 900 505 VAN NESS AVENUE SAN FRANCISCO, CA 94111 SAN FRANCISCO, CA 94102-3214

CATHIE ALLEN DIR - REGULATORY AFFAIRS PACIFICORP 825 NE MULTNOMAH ST., STE 300 PORTLAND, OR 97232

State Service

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JULIE A. FITCH VALERIE KAO CALIF PUBLIC UTILITIES COMMISSION CALIF PUBLIC UTILITIES COMMISSION ADMINISTRATIVE LAW JUDGE DIVISION ADMINISTRATIVE LAW JUDGE DIVISION ROOM 5107 ROOM 5005 505 VAN NESS AVENUE 505 VAN NESS AVENUE SAN FRANCISCO, CA 94102-3214 SAN FRANCISCO, CA 94102-3214

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ADVICE LETTER SUMMARY...Advice Letter No. 588-E September 3, 2019 Page 2 Specifically, Ordering...

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