20110110Staff 1-19 to IPC.pdf

rWELDON B. STUTZMAN
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
472 WEST WASHINGTON STREET
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
BARNO. 3283
im! JAM' 0 PM 2: 55
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Street Address for Express Mail:
472 W. WASHINGTON
BOISE, IDAHO 83702-5918
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION OF )
IDAHO POWER COMPANY REQUESTING )
APPROVAL OF REVISIONS TO THE )
IRRGATION PEAK REWARDS PROGRAM, )SCHEDULE 23. )
)
)
)
CASE NO. IPC-E-I0-46
FIRST PRODUCTION
REQUEST OF THE
COMMISSION STAFF TO
IDAHO POWER COMPANY
The Staff of the Idaho Public Utilties Commission, by and through its attorney of record,
Weldon B. Stutzman, Deputy Attorney General, requests that Idaho Power Company (Company;
IPC) provide the following documents and information as soon as possible, but no later than
MONDAY, JANUARY 31, 2011.
This Production Request is to be cònsidered as continuing, and Idaho Power Company is
requested to provide, by way of supplementary responses, additional documents that it or any
person acting on its behalfmay later obtain that will augment the documents produced.
For each item, please indicate the name of the person(s) preparing the answers, along with
the job title of such person(s) and the witness who can sponsor the answer at hearng.
FIRST PRODUCTION REQUEST TO
IDAHO POWER COMPANY 1 JANUARY 10,2010
REQUEST NO.1: On page 3 of the Application, the Company "concluded that its anual
capacity need during the highest 60 hours of demand is expected to vary by more than 50 percent
(167 megawatts) during the next five years." Please describe all the parameters used in the model
to reach this conclusion, and provide all executable electronic regression models, along with
descriptions of accuracy (i.e., - descriptive statistics).
REQUEST NO.2: On pages 4 and 5 of the Application, the Company describes the
incentive payment for "Extended Interrption" paricipants. Please explain how the Company
arived at the "Extended Interrption" Incentive amount. As par of your response, explain how
the Company arived at the incentive difference between the "Stadard Interrption" and the
"Extended Interrption." Please provide the supporting executable electronic workpapers.
REQUEST NO.3: On page 5 of the Application, the Company describes changes to
the way load reduction is calculated for the Dispatchable Option 3 credit payment. Please fully
explain why the Company chose to use "average demand between 10:00 p.m. and 11 :00 a.m. MDT
prior to an event" for calculating the load reduction rather than average demand over the prior 24-
hour period. Please provide the supportingeAecutable electronic workpapers.
REQUEST NO.4: On page 8 of the 2009 Annual DSM Report, the Company states
"Next to distributed generation, the Company's çlemand response programs are the least-cost
resource for meeting summer peak loads over the 20-year IRP planing period." Please compare
the cost (per kW and kWh at generation) of the Irrigation Load Control Program with the cost (per
kW and kWh at generation) of the resources anticipated to be necessar over the next 10 years. As
par of your answer, please explain your net present value (NPV) assumptions. Please provide the
supporting executable electronic workpapers.
REQUEST NO.5: On pages 16-17 of Pete Pengily's Testimony, he describes a
connection between the variabilty of forecasted demand in the resource adequacy analysis and
the Company's proposed 40 percent fixedíand 60 percent varable incentive payment. On page 17,
lines 2-5, he says "the Company believes that the 60 percent varable payment structure is
reflective of the variations in cost that would exist under a variable paricipation approach."
FIRST PRODUCTION REQUEST TO
IDAHO POWER COMPANY 2 JANUARY 10, 2010
Please explain whether varability in the need for demand response wil be the basis for
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determining the fixed versus variable'incentive structure moving forward. As par of your
.
response, please explain why you did not mirror the results of the projected demand response
variabilty analysis by setting the incentive payment at 50 percent fixed and 50 percent variable.
REQUEST NO.6: Page l7, lines 5-7 of Pete Pengily's Testimony, he states "the
Company anticipates that the proposed le~eiÓffixed incentive wil be adequate to retain current
paricipants." Please describe the studies, revl~ws,~rinarket research used that supports the
Company's conclusion. As par ofyouirJspon~e, please provide the supporting electronic
workpapers (e.g. - program maturity or market saturation evaluations).
REQUEST NO.7: In executable electronic format, for 2010 please provide the:
a. Amount of money paid to irrigators in credit payments,
b. Number of anual events called per season,
c. Duration of each event;
d. Percentage of paricipants curiled during each event,
e. Variation in hours curailed for each paricipant during each event,
f. Total hours curailed for each paricipant in each season. If the maximum number
of curiled hours per participant was not used during any paricular season, please
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explain' why.
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REQUEST NO.8: What would.interrPtions have been in 2010 if the proposed program
incentive structure had been in place? How much money would have been paid to paricipating
irrigators in credit payments? How would administrative costs change?
REQUEST NO.9: On Exhibit 2 of Pete Pengily's Testimony, the Company provides a
table ilustrating the modified incentive payment structure based on a hypothetical paricipant with
a 125 horsepower pump. Please provide the impactof program changes on customers with the
average or median size pumps.
FIRST PRODUCTION REQUEST TO
IDAHO POWER COMPANY 3 JANUARY 10,2010
REQUEST NO. 10: Has the Company considered increasing the Dispatchable Option 3
cumulative horsepower requirement for prograr paricipation? Has the Company considered
initiating a cumulative horsepower requiremi:mt for påricipation in its other dispatchable options?
In both cases, why were proposals not made?
REQUEST NO. 11: In 2010, what percentage of Irrgation Load Control Program
paricipants used dispatchable load control devices versus timer based load control devices? In
2010, what percentage of the enrolled Irrgation toad Control Program curailment came from
dispatchable load control devices vs. timer based.:îda:dcontrol devices?
REQUEST NO. 12: When the Company provides the monthly "Bil Credit" to
participating customers, what percentage of paricipants have historically chosen to receive a check
in the mail, and how many have chosen to have the credit amount applied directly to the bil. As
par of your response, please provide the Company's total annual administrative cost differences
associated with each selection.
REQUEST NO. 13: On page 2 of the Application, the Company states that it "enhanced
its traditional anual review by conducting an additional study in conjunction with its 2011
Integrated Resource Plan ("IRP") analysis. This study was conducted in an effort to ensure that
the Program's design is aligned with the resource needs identifed in the IRP." Please provide the
full study, along with' the executable electroniè' copy of the workpapers.
REQUEST NO. 14: On Exhibit 1, page 2 of Pete Pengily's Testimony, he shows the
Company's "Theoretical 2011 Dispatch of310 MW of Demand Response." The Exhibit shows
the interrptions being spread over seven hours, as.opposed tothe four that are listed in the tariff
for individual customers. Please explain how the interrptions are typically spread into phases
throughout an event, and how the interrptions'are managed throughout the season.
REQUEST NO. 15: On Exhibit 1, page3 of Pete Pengily's Testimony, he provides a
graph to ilustrate the Company's projected need for demand response over the planing period.
Why was the highest 60 hours per year used to determine 306 MW of potential demand reduction
FIRST PRODUCTION REQUEST TO
IDAHO POWER COMPANY 4 JANUARY 10,2010
when Exhibit No.1, page 1 of Pete Pengily's Tes,timony, shows Irrigators interrptions occurring
in three phases over 5 total hours (more than an events maximum of 4 hours per paricipant)?
What would be the result if potential demand were based on more than 60 hours (e.g.-80 hours) to
reflect the event interruptions being deployed over several phases?
REQUEST NO. 16: On Exhibit 1, page 3 of Pete Pengily's Testimony, he provides a
graph to ilustrate the Company's projected need for'demand response over the planing period
under extreme load conditions. Please provide àctual.2010 data on this graph, and explain how
including it might change the outcome of your variabilty analysis and incentive structue?
i
REQUEST NO. 17: When comparng the proposed "Fourh Revised Sheet No. 23-5" to
the curent "Third Revised Sheet No. 23-5," it appears the Company's proposal eliminates the
opportunity for Dispatchable Option 3 participants to "manually interrpt electric service to
paricipating irrigation pumps dúling loadconttoLevents." However, under "Program
Description" on the "Fourh Revised SheetNo. 23-1," it states "In limited applications, a select
group of eligible Customers will be permitted to manually interrpt electric service to paricipating
irrigation pumps durng load control events (See Dispatchable Option 3)." Does the Company's
proposal eliminate the opportunity for Dispatchable Option 3 paricipants to "manually interrpt
electric service to paricipating irrigation pumps during load control events"? If so, please explain
why this is the proposal, and how it will impact customers.
REQUEST NO. 18: On Exhibit 1, page 4 of Pete Pengily's Testimony, please explain
why the:
a. "Peak Load" (Column B) drops by 85 MW between 2011 and 2012.
b. "60th Hour Peak Load" (Column C) increases by 18 MW between 2011 and 2012 when
the "Peak Load" (Column B) drops over the same period.
c. "L&R Balance Deficit Position w/oDR\Progrars" (Column F) drops by 223 MW
between 2011 and 2012.
d. "Operational Target" (Column I) is higher than the "Demand Response Target"
(Colum H) in some years and lower in other years. How is this "Operational Target"
determined?
FIRST PRODUCTION REQUEST TO
IDAHO POWER COMPANY 5 JANUARY 10,2010
REQUEST NO. 19: On Exhibit 1, page 3 of Pete Pengily's Testimony, please explain
why the peak load hour in 2012 is greater than in 2011, when Exhibit 1, page 4 of Pete Pengily's
Testimony shows "Peak Load" in 2012 being less than 2011.
i .~DATED at Boise, Idaho, this \0 day of January 2011.
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Weldon B. StUan
Deputy Attorney General
Technical Staff: Matt Elam
i:umisc:prodreq/ipceI0.46wsme prod reqI
FIRST PRODUCTION REQUEST TO
IDAHO POWER COMPANY 6 JANUARY 10,2010
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 10th DAY OF JANUARY 2011,
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF THE COMMISSION
STAFF TO IDAHO POWER COMPANY, IN CASE NO. IPC-E-1O-46, BY MAILING A
COPY THEREOF, POSTAGE PREPAID, TO THE FOLLOWING:
LISA D NORDSTROM
DONOV AN E WALKER
IDAHO POWER COMPANY
PO BOX 70
BOISE ID 83707-0070
E-MAIL: lnordstrominidahopower.com
dwalkerinidahopower.com
GREG SAID
SCOTT SPARKS
IDAHO POWER COMPANY
PO BOX 70
BOISE ID 83707-0070
E-MAIL: gsaidinidahopower.com
ssparksinidahopower .com
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CERTIFICATE OF SERVICE