20091207_2778.pdf

DECISION MEMORANDUM
TO:COMMISSIONER KEMPTON
COMMISSIONER SMITH
COMMISSIONER REDFORD
COMMISSION SECRETARY
LEGAL
WORKING FILE
FROM:BRY AN LANSPERY
DATE:DECEMBER 4, 2009
RE:IDAHO POWER COMPANY TARIFF ADVICE 09-12;
MODIFICATIONS TO SCHEDULE 23
On November 20 2009, Idaho Power Company ("Company ) submitted modifications to
Schedule 23 , Irrigation Peak Rewards Program ("Program ). The Program is an optional service
in which participating Schedule 24 customers permit the Company to turn off specified irrigation
pumps during the Program season in return for a financial incentive payment. According to the
Company s filing, a meeting was held with the Idaho Irrigation Pumpers Association ("lIP A") on
October 8, 2009 to review the first season of the Program. As a result, it was deemed by the
parties that the Program could be enhanced by a number of minor alterations. Specifically, the
Company s filing modifies the length of the Program season, eligible days and hours of
implementation, and the manner in which the financial incentive is awarded to participating
irrigators. It is noted that these modifications do not adversely impact the financial incentives
nor the cost-effectiveness of the Program.
Regarding the length of the Program, the Company proposes to define the Program
season to be June 15 through August 15 each year. Last year the season ended on July 31. Staff
believes that extending the Program an additional couple of weeks into August has merit as it
provides the Company with greater flexibility to dispatch the load control option during periods
when it would provide the greatest benefit. Traditionally, local temperatures in early August
have been near or above July temperatures, generally corresponding to higher power supply
costs.
DECISION MEMORANDUM - 1 -DECEMBER 4, 2009
The Company also proposes to extend the eligible hours for interruption during the day
by starting at 1 :00 pm DST rather than the current 2:00 pm. Also, the Company proposes to
include Saturday as a potential day for interruption where the prior year was constrained to
weekdays only. Again, Staff notes that these modifications serve to increase the flexibility of the
Program operation and that the Company will continue to operate in a manner that maximizes
the benefits of the load reduction. The Company has accordingly changed the language in the
tariff to maintain the half-hour notice to participants should a pending load control notice be
revoked.
The Company proposes two changes affecting participants with multiple pumps and at
least 1 000 cumulative horsepower (Option 3). Last season, Program KW was based on the
difference between the monthly billing demand less average demand. Next season the Company
proffers to base this on the maximum measured interval demand during the 24-hour period
immediately preceding the event minus the average demand during the event. Staff believes this
to be a more accurate method for calculating Program KW for large participants. Also, Option 3
customers that manually interrupt service (as opposed to using the two-way communicating
device) would receive the financial credit within 30 days of billing rather than the following
corresponding bill. The Company requests this due to the extensive data needed to calculate and
process interval metering data. Staff does not believe this unduly harms participants and in no
way discourages participation.
Finally, the Company proposes clarifying language regarding the payment of the
financial incentive. The Company proposes removing ambiguous language stating that the
payment would be in the form of either a check or Bill Credit in favor of distributing incentives
primarily through a Bill Credit corresponding to the Program season. Any remaining balance
would then be issued through a check.
Staff has debated this issue before with Rocky Mountain Power s Irrigation Load Control
Program (Case No. PAC-09-1). Staff believes it is appropriate to provide payment directly
through customer bills as it reduces administrative costs and has the ancillary benefit of reducing
uncollectables and delinquent accounts, which benefits the class as a whole. lIP A actively
participated in Case No. P AC-09-1 and concluded that issuing bill credits in lieu of checks
would not adversely impact participation in the Irrigation Load Control Program. Given that this
DECISION MEMORANDUM - 2 -DECEMBER 4 , 2009
filing is a direct result of lIP A and Company meetings, Staff assumes the same is true for
participants in Idaho Power s Program.
STAFF RECOMMENDATION
Staff has reviewed the Company s filing and has noted either its support for the proposed
changes or its belief that the Program is held unharmed by the modifications. Staff again notes
that these modifications are a direct result of the Company and lIP A meeting. Staff has
confirmed with the lIP A. that the proposed changes reflect the discussion that took place in
October and it has no issue with the submitted tariff language. Staff therefore recommends that
the Commission approve the modifications to Schedule 23 as submitted by the Company.
CO MMISSI 0 N D ECISI
Does the Commission wish to accept Idaho Power Company s modifications to Schedule
, Irrigation Peak Rewards Program, as submitted, with an effective date of January 4, 2010?
i:udmemos/decision memorandum schedule 23.doc
DECISION MEMORANDUM - 3 -DECEMBER 4 , 2009