20241217Staff Comments.pdf

RECEIVED
Tuesday, December 17, 2024 11:53:23 AM
IDAHO PUBLIC
UTILITIES COMMISSION
MICHAEL DUVAL
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 11714
Street Address for Express Mail:
11331 W CHINDEN BLVD, BLDG 8, SUITE 201-A
BOISE, ID 83714
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF IDAHO POWER )
COMPANY'S APPLICATION FOR ) CASE NO. IPC-E-24-37
MODIFICATIONS TO THE COMPANY'S )
IRRIGATION DEMAND RESPONSE )
PROGRAM, SCHEDULE 23 AND ) COMMENTS OF THE
COMMERCIAL & INDUSTRIAL DEMAND ) COMMISSION STAFF
RESPONSE PROGRAM, SCHEDULE 82 )
COMMISSION STAFF ("STAFF") OF the Idaho Public Utilities Commission
("Commission"), by and through its Attorney of record, Michael Duval, Deputy Attorney
General, submits the following comments.
BACKGROUND
On September 30, 2024, Idaho Power Company("Company") applied to the Commission
for an order granting revisions to its Irrigation Peak Rewards Program(Schedule 23) and its Flex
Peak Program(Schedule 82) ("Application"). The Company requested a final order by January
31, 2025.
In its Application, the Company proposes to: (1)begin variable payments for the Flex
Peak and Irrigation Peak Rewards on the fourth event, (2) add an early interruption option to the
Irrigation Peak Rewards program, (3) add clarifying language to Schedule 23 for group C
participants, (4) add clarifying language around emergency dispatch to Schedule 23, (5) add an
STAFF COMMENTS 1 DECEMBER 17, 2024

incentive for Flex Peak participants that automate their systems, (6)update the baseline cap
calculation for Flex Peak event days, (7) add language to the "day-of' load adjustment process,
and(8) increase the nomination flexibility of Flex Peak participants. Finally, the Company
requested the Commission issue an order by January 31, 2025.
STAFF ANALYSIS
Staff reviewed the Company's Application,proposed tariffs, and discovery responses.
Most proposed modifications are adjustments to existing Tariff language (See proposals three,
four, six, and seven) and incremental adjustments to the demand response ("DR")program's
operations. The Company's first, second, and fifth proposed modifications have a direct impact
on the cost-effectiveness of the respective programs. Staff believes that the sum of all the
proposed changes in the Application will improve customer satisfaction with the programs and
that the programs will remain cost-effective; therefore, Staff recommends approval of the
Application and proposed tariffs. However, the changes also present additional risks that merit
monitoring.
Early Dispatch Option
In its second proposed modification, the Company proposes to add an early interruption
option to the Irrigation Peak Rewards program for interruptions occurring no later than 9 pm
with a reduced incentive ("Early Interruption"). The Company estimates that the Early
Interruption option will bring an additional 20 MW of capacity to the Irrigation Peak Rewards
program and shift 20 MW of existing capacity to the earlier option. The Company expects the
Early Interruption option to remain cost-effective with these shifts. Response to Production
Request No. 2. Because the window for the Early Interruption is during less valuable times, the
proposed option offers half the incentive of the standard dispatch option. Staff believes a
reduced incentive is appropriate for the Early Interruption to reflect the less valuable hours. Staff
verified the Company's calculations supporting the cost-effectiveness of the proposed Early
Interruption program . However, Staff is concerned with shift away from the timeframes when
capacity is most needed.
This change represents some amount of back tracking to the expanded dispatch option
approved in Order No. 35336. In that case, the Company shifted the dispatch hours of the Peak
STAFF COMMENTS 2 DECEMBER 17, 2024

Rewards program later in day to increase reliability on the system. After implementing this
change, the Company saw a reduction of approximately 40 MW in program capacity as some
participants were unwilling to reduce load in later hours. Staff is concerned that the addition of a
more convenient dispatch window may lead to a larger shift in participation to the less valuable
option than the Company estimates. Staff recommends that the Company monitor the
participation in each of the Peak Rewards interruption options. Staff will review the
participation, reduction capacity, and impact to the Company system as part of the Company's
annual DSM filings.
Nomination flexibility
In its eighth proposed modification, the Company proposes to allow Flex Peak
participants to adjust their nominations at any time during the DR season. The Company states
that the increased nomination flexibility will enhance the accuracy of nominations. Accurate
representation of the capacity that can be reduced by the program is important; however, Staff
believes that the increased flexibility may also lead to increased variability in the reduction
capacity of the Flex Peak program. Staff will review flex peak program performance as part of
the Company's regular annual reports.
STAFF RECOMMENDATION
Staff recommends that the Commission approve the Company's Application and
proposed tariffs as filed.
Respectfully submitted this 17th day of December 2024.
1
Dayn rdie for Michael Duval
Deputy Attorney General
Technical Staff. Jason Talford
I:\Utility\UMISC\COMMENTS\IPC-E-24-37 Comments.docx
STAFF COMMENTS 3 DECEMBER 17, 2024

CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS,]7 DAY OF DECEMBER 2024,
SERVED THE FOREGOING COMMENTS OF THE COMMISSION STAFF, IN CASE
NO. IPC-E-24-37, BY E-MAILING A COPY THEREOF, TO THE FOLLOWING:
MEGAN GOICOECHEA ALLEN CONNIE ASCHENBRENNER
LISA D NORDSTROM MARY ALICE TAYLOR
IDAHO POWER COMPANY IDAHO POWER COMPANY
PO BOX 70 PO BOX 70
BOISE ID 83707-0070 BOISE ID 83707-0070
E-MAIL: E-MAIL: caschenbrenner(.idahopower.com
mgoicoecheaallengidahopower.com mtaylorgidahopower.com
lnord stromkidahopower.com
dockets Jdahopower.com
PATR CIA JORDAN, SECATARY
CERTIFICATE OF SERVICE