SALT LAKE CITY — Rocky Mountain Power and its consultants briefed the Utah Public Service Commission and stakeholders Wednesday on how the company measures the cost effectiveness of demand‑side management programs and on proposed clarifications to reporting practices.

Michael Snow, a Rocky Mountain Power representative, opened the technical conference by saying the meeting's purpose was “to just present information” and to answer questions about cost‑effectiveness methodologies, avoided costs and related calculations.

The presentation, led by Eli Morris, senior director at ICF, summarized standard cost‑effectiveness tests derived from the California Standard Practice Manual and recent national guidance. Morris said jurisdictions still use five canonical tests — the utility (program administrator) cost test (UCT), total resource cost (TRC) test, participant cost test, ratepayer impact measure (RIM) and societal cost test — and explained how benefits and costs are included differently in each. “We're talking specifically about cost effectiveness of demand side management programs,” Morris said.

Why it matters: commissioners and stakeholders said the outcome of how Rocky Mountain Power defines the planning threshold affects which DSM measures the company will prioritize, how the company presents public filings and how rate impacts are analyzed. Jennifer Eden of Utah Clean Energy asked, “How does the company prioritize DSM as a resource as opposed to as a filler?” reflecting broader concern about DSM's role relative to supply‑side resources in the company's integrated resource plan (IRP).

Key points from the conference

- Company proposal and reporting: Rocky Mountain Power said it intends to continue reporting results for multiple tests but asked the commission to clarify that, for forward program planning, the UCT will serve as the primary planning threshold (that is, the company will design programs to pass the UCT at a minimum). Company representatives said they would continue to provide TRC, RIM, participant and other test results, and sensitivity analyses, in annual reports.

- TRC decline and market change: presenters and company staff said the TRC result for residential measures has fallen in recent years largely because residential lighting savings from LEDs have largely disappeared. The company noted that low incremental costs for earlier lighting measures had supported higher TRC results; as lighting savings have diminished and remaining residential measures (for example, building envelope and HVAC upgrades) carry much higher customer costs, the TRC for the residential portfolio has dropped. A Rocky Mountain Power representative said the residential TRC has fallen to roughly 0.65 in recent reporting.

- RIM test behavior: Morris and others explained that the RIM test commonly shows lower cost‑effectiveness results because it treats lost utility revenue as a cost; energy efficiency reduces volumetric sales and leaves fixed costs to be recovered on fewer kilowatt‑hours. Stakeholders asked whether the RIM calculation accounts for expected load growth; presenters said avoided costs are driven by the IRP and the analysis uses current retail rate assumptions for the RIM calculation unless a jurisdiction explicitly builds rate‑design changes into the test.

- Avoided‑cost methodology and the IRP: Rocky Mountain Power staff said avoided energy, capacity, transmission and distribution values come from the company's IRP modeling and are provided on an hourly basis. Morris showed representative net‑present‑value dollars per megawatt‑hour for typical end uses, noting higher values for measures with summer‑coincident savings (for example, cooling) and lower values for winter‑coincident savings (heating). As an example, the presentation showed that a cooling measure with a long useful life produced substantially higher NPV per MWh; presenters described a 20‑year cooling measure as generating on the order of $1,500 per MWh NPV in their illustrative chart.

- Jurisdictional differentiation: Stakeholders asked how avoided costs for Utah customers are isolated from the six‑state Pacificorp system. Clay Monroe of Rocky Mountain Power said the company does differentiate avoided costs by state, though he deferred detailed methodology questions to the IRP team.

Stakeholder reactions and next steps

- Support for collaboration: Commissioners and stakeholder representatives acknowledged multi‑party collaboration on the filing. Commissioner John Harvey thanked participants for the collaborative process.

- Requests for clarity: Stakeholders including Western Resource Advocates and Utah Clean Energy pressed the company on how DSM targets from the IRP are translated into program priorities and asked for continued transparency about how DSM is treated relative to supply resources.

- No formal decision: The technical conference was informational; commissioners did not issue an immediate ruling. Rocky Mountain Power said it will continue to include multiple cost‑effectiveness tests and sensitivity analyses in its annual reporting and to work with the PSC and steering committee members on implementation details of the proposed clarification.

Meeting context and scope

The exchange focused on methodology and reporting, not on new program approvals or votes. Presenters repeatedly distinguished between (a) discussion of test methodology and avoided costs, (b) planning direction the company intends to follow (using the UCT as a primary planning threshold while continuing to report other tests), and (c) formal commission actions, which were not taken at the conference.

No formal decisions were recorded during the conference; participants were told follow‑up questions could be handled offline and technical details on IRP methodology would be addressed by the IRP team or in subsequent filings.