20110131IPC to IIPA 1-17.pdf

eslDA~POR~
An IDACORP Company
LISA D. NORDSTROM
Lead Counsel
Inordstrom~idahopower.com
January 28, 2011
VIA HAND DELIVERY
Jean D. Jewell, Secretary
Idaho Public Utilities Commission
472 West Washington Street
P.O. Box 83720
Boise, Idaho 83720-0074
Re: Case No. IPC-E-10-46
IN THE MATTER OF THE APPLICA TlON OF IDAHO POWER COMPANY
FOR APPROVAL OF REVISIONS TO THE IRRIGA TlON PEAK REWARDS
PROGRAM, SCHEDULE 23
Dear Ms. Jewell:
Enclosed for filng please find an original and three (3) copies of Idaho Power
Company's Response to the Idaho Irrigation Pumpers Association, Inc.'s (UIIPA") First Data
Request to Idaho Power Company in the above matter.
Also enclosed are four (4) copies each of non-confidential and confidential disks
containing documents being produced in response to IIPA's Data Request.
Lastly, enclosed is a Protective Agreement Idaho Power Company requests the
parties execute to receive certain data. Once the Protective Agreement has been
executed, the confidential information wil be distributed to the parties.
Very truly yours,
/:", fJ'i (K~
Lisa D. Nordstrom
LDN:csb
Enclosures
1221 W. Idaho St. (83702)
P.O. Box 70
Boise, 10 83707
CERTIFICATE OF ATTORNEY
ASSERTION THAT MATERIALS REQUESTED AND PROVIDED DYl\~&'WE PM ll: 3 t
COURSE OF AN IDAHO PUBLIC UTILITIES COMMISSION PROCEEilJ~~~);~1,":u\~Ç:,\Oi.\
ARE PROTECTED FROM PUBLIC INSPECTION LITiUTk~) t,v,,"""''JI-
Case No. IPC-E-10-46
The undersigned attorney, in accordance with RP 233, hereby certifies that
Attachments 1 and 2 provided by Idaho Power Company in response to the Idaho
Irrigation Pumpers Association, Inc.'s Request No.7 contain information that is a trade
secret or privileged or confidential as described in Idaho Code § 9-340, et seq., and §
48-801, et seq., and as such are exempt from public inspection, examination, or
copying.
DATED this 28th day of January 2011.
~f2.t1J4~Lisa D. Nordstrom
Counsel for Idaho Power Company
LISA D. NORDSTROM (ISB No. 5733)
DONOVAN E. WALKER (ISB No. 5921)
Idaho Power Company
P.O. Box 70
Boise, Idaho 83707
Telephone: [phone]
Facsimile: [phone]
Inordstromcmidahopower.com
dwalkercmidahopower.com
Attorneys for Idaho Power Company
Street Address for Express Mail:
1221 West Idaho Street
Boise, Idaho 83702
R:E(~f:~
ZUi 28 Pl'l 4: 31
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION
OF IDAHO POWER COMPANY FOR
APPROVAL OF REVISIONS TO THE
IRRIGATION PEAK REWARDS
PROGRAM, SCHEDULE 23
)
) CASE NO. IPC-E-10-46
)
) IDAHO POWER COMPANY'S
) RESPONSE TO THE IDAHO
) IRRIGATION PUMPERS
) ASSOCIATION, INC.'S FIRST DATA
) REQUEST TO IDAHO POWER
) COMPANY
)
COMES NOW, Idaho Power Company ("Idaho Powet' or "Company"), and in
response to the Irrigation Pumpers Association, Inc.'s First Data Request to Idaho
Power Company dated January 7,2011, herewith submits the following information:
IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO IRRIGATION
PUMPERS ASSOCIATION, INC.'S FIRST DATA REQUEST TO IDAHO POWER COMPANY - 1
REQUEST NO.1: The current Schedule 23 under the heading of "Demand
Credit" states: "This amount may be prorated for the number of days during the Months
of June, July, and August that fall in the Customets billng cycle to correspond with the
Program Season." This interrogatory is focused upon the words "may be prorated".
a. In the past, has the Company prorated the demand credits?
b. If the Company has prorated the demand credits, were all demand credits
prorated? If not, what approximate percentage was not prorated?
c. Upon what basis did the Company prorate some demand credits and not
others?
d. Regarding the customers under the Dispatchable Option, how many does
the Company have with specific daily/hourly data that can be used for
determining the "Program Season" usage? How many kW are involved
with these customers?
RESPONSE TO REQUEST NO.1:
a. Yes, the Company has prorated demand credits since the beginning of the
program in 2004.
b. No, demand credits were only prorated for June and August because
those months overlap the beginning and end dates of the program. Demand Credits
are also prorated if a customer started or stopped service during the program period.
Every Peak Rewards Program ("Program") participant has received a prorated credit,
due to reading/biling cycles not fallng perfectly on program season dates.
c. Credits are prorated for periods when reading/biling cycles do not align
with the Program Season dates from June 15 to August 15.
d. As a point of clarification, Idaho Power does not calculate or utilize usage
from the Program Season for any participants even though the data is available on a
few customers that have interval metering. Out of a total of 2,038 service locations
IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO IRRIGATION
PUMPERS ASSOCIATION, INC.'S FIRST DATA REQUEST TO IDAHO POWER COMPANY - 2
participating in the Program in 2010, Idaho Power has interval meter data on 69 service
locations with normal load research meters and an additional 30 customers on Option 3.
Usage during the Program Season is obtained from normal billng cycle meter reads
and biling cycle peak demand reads. The interval meter data obtained from the
participants under Option 3 is used to determine load reduction during events and what
their base load is prior to events. The total biling kilowatts ("kW") on the 69 service
locations is 22,069 kW and for the Option 3 service locations it is 59,837 kW.
The response to this Request was prepared by Peter Pengily, Customer
Research & Analysis Leader, Idaho Power Company, in consultation with Lisa D.
Nordstrom, Lead Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO IRRIGATION
PUMPERS ASSOCIATION, INC.'S FIRST DATA REQUEST TO IDAHO POWER COMPANY - 3
REQUEST NO.2: Under the existing Schedule 23, for a customer taking service
under the Dispatchable Option 1 or 2 with the following parameters, please list each of
the Demand and Energy Credits that would be provided. Please provide all calculations
and assumptions used to develop these figures.
a. 100 kW demand
b. Meter readings occurring on the first of the month with no specific
provision to calculate the actual usage each hour.
c. 168 hours of operation between June 1 and June 14
d. 300 hours of operation between June 15 and June 30
e. 300 hours of operation between July 1 and July 15
f. 168 hours of operation between July 16 and July 31
g. 168 hours of operation between August 1 and August 15
h. 100 hours of operation between August 16 and August 31.
RESPONSE TO REQUEST NO.2: In the operation of the Program, Idaho
Power does not have the actual hours of operation between the dates as specified in
the Request above for Dispatachable Option 1 and 2 participants. The Company uses
regular reading/biling cycle meter reads to calculate the incentives for Dispatachable
Option 1 and 2 participants. Program incentives are prorated by the days that fall within
the Program Season divided by the number of days in a biling cycle. Therefore, for
purposes of this example, the hours of operation listed above (c-h) were combined for a
single number of operating hours per month to calculate the incentives.
IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO IRRIGATION
PUMPERS ASSOCIATION, INC.'S FIRST DATA REQUEST TO IDAHO POWER COMPANY - 4
Program
Read Season Demand Credit Energy Credit Total
Date Days kW kWh Days Hours ($)($)Credit ($)
(a)( b )(c )(d)( e )( f)(Q)( h )( i )
(c)x(f)( e )/( b )x( c)x$4.65*( e )/( b )x( d )x$.031 **(a)+(h)
June
UsaQe 7/1/2009 30 100 46,800 15 468 $232.50 $725.40 $957.90
July
UsaQe 8/1/2009 31 100 46,800 31 468 $465.00 $1,450.80 $1,915.80
August
Usage 9/1/2009 31 100 26,800 15 268 $225.00 $402.00 $627.00
* $4.65 = Demand Credit Total $3,500.70
**$0.031 = Energy Credit
The response to this Request was prepared by Peter Pengily, Customer
Research & Analysis Leader, Idaho Power Company, in consultation with Lisa D.
Nordstrom, Lead Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO IRRIGATION
PUMPERS ASSOCIATION, INC.'S FIRST DATA REQUEST TO IDAHO POWER COMPANY - 5
REQUEST NO.3: Under the existing Schedule 23, for a customer taking service
under the Dispatchable Option 1 or 2 with the following parameters, please list each of
the Demand and Energy Credits that would be provided. Please provide all calculations
and assumptions used to develop these figures.
a. 100 kW demand
b. Meter readings occurring on the first of the month with no specific
provision to calculate the actual usage each hour.
c. 234 hours of operation between June 1 and June 14
d. 234 hours of operation between June 15 and June 30
e. 234 hours of operation between July 1 and July 15
f. 234 hours of operation between July 16 and July 31
g. 168 hours of operation between August 1 and August 15
h. 100 hours of operation between August 16 and August 31.
RESPONSE TO REQUEST NO.3: The hours between read dates are exactly
the same (468 for June, 468 for July and 268 for August) as in the Idaho Irrigation
Pumpers Association, Inc.'s ("IIPA") Request No.2. Therefore, the Company's
Response to IIPA's Request No.3 is the same as the Company's Response to IIPA's
Request No.2. As stated in the Company's Response to Request NO.2, Idaho Power
uses regular billng cycle meter reads to calculate the incentives for Dispatachable
Option 1 and 2 participants. The incentives for the Program are prorated by the days
that fall within the program period divided by the number of days in a billng cycle.
The response to this Request was prepared by Peter Pengily, Customer
Research & Analysis Leader, Idaho Power Company, in consultation with Lisa D.
Nordstrom, Lead Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO IRRIGATION
PUMPERS ASSOCIATION, INC.'S FIRST DATA REQUEST TO IDAHO POWER COMPANY - 6
REQUEST NO.4: Under the existing Schedule 23, for a customer taking service
under the Dispatchable Option 1 or 2 with the following parameters, please list each of
the Demand and Energy Credits that would be provided. Please provide all calculations
and assumptions used to develop these figures.
a. 100 kW demand
b. Meter readings occurring on the first of the month with no specific
provision to calculate the actual usage each hour.
c. 300 hours of operation between June 1 and June 14
d. 168 hours of operation between June 15 and June 30
e. 100 hours of operation between July 1 and July 15
f. 0 hours of operation between July 16 and July 31
g. 0 hours of operation between August 1 and August 15
h. 0 hours of operation between August 16 and August 31.
RESPONSE TO REQUEST NO.4: Please see the description of the analysis
provided in the Company's Response to IIPA's Request NO.2 above.
Program
Read Season Demand Credit Energy Credit Total
Date Days kW kWh Days Hours ($)($)Credit ($)
( a )( b )(c )( d)(e)( f)( g)(h)( i )
(c)x(f)( e )/( b )x( c )x$4.65*( e )/( b )x( d )x$.031 **(o)+(h)
June
Usaoe 7/1/2009 30 100 46,800 15 468 $232.50 $725.40 $957.90
July
Usaoe 8/1/2009 31 100 10,000 31 100 $465.00 $310.00 $775.00
August
Usaoe 9/1/2009 31 100 0 15 0 $225.00 $0.00 $225.00
* $4.65 = Demand Credit Total $1,957.90
**$0.031 = Energy Credit
IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO IRRIGATION
PUMPERS ASSOCIATION, INC.'S FIRST DATA REQUEST TO IDAHO POWER COMPANY - 7
The response to this Request was prepared Peter Pengily, Customer Research
& Analysis Leader, Idaho Power Company, in consultation with Lisa D. Nordstrom, Lead
Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO IRRIGATION
PUMPERS ASSOCIATION, INC.'S FIRST DATA REQUEST TO IDAHO POWER COMPANY - 8
REQUEST NO.5: In the existing Schedule 23 the Demand and Energy credits
are to be calculated based upon the "usage that occurs during the calendar months of
June, July, and August of each year." For 2009 and 2010, what was the total demand
credit for June, July, and August? What was the total energy credit for June, July, and
August in 2009 and 2010?
RESPONSE TO REQUEST NO.5: The table below shows the credits for both
2009 and 2010. In addition, September is included in the chart because reading/billng
cycles push some credits into September.
2009 June July Aug Sept Totals
kW $515,209 $1,138,306 $649,074 $28,920 $2,331,509Credit
kWh $819,048 $2,223,307 $1,459,639 $37,192 $4,539,186Credit
$6,870,694
2010 June July Aug Sept Totals
kW $214,278 $1,353,007 $1,365,301 $213,685 $3,146,272Credit
kWh $432,354 $3,848,639 $3,654,559 $413,448 $8,348,999Credit
$11,495,271
The response to this Request was prepared by Peter Pengily, Customer
Research & Analysis Leader, Idaho Power Company, in consultation with Lisa D.
Nordstrom, Lead Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO IRRIGATION
PUMPERS ASSOCIATION, INC.'S FIRST DATA REQUEST TO IDAHO POWER COMPANY - 9
REQUEST NO.6: Please provide a graph similar to Exhibit 1 page 1 (with
support data presented in tabular form) for each day during 2009 and 2010 when there
was an interruption/curtailment to either the Residential, Commercial, or Irrigation
customers. Please include in tabular form the timing and magnitude of each
interruptions as listed on Exhibit 1 page 1 .
RESPONSE TO REQUEST NO.6: Please see the following Excel files provided
on the enclosed CD: Attachment 1, 2009 5 Minute Load Data; Attachment 2, 2010 5
Minute Load Data; and Attachment 3, Dispatch Days 2009 2010. Attachments 1 and 2
contain the five minute system load data for all demand response dispatch days in 2009
and 2010. Attachment 3 contains the days and hours that the programs were
dispatched.
The response to this Request was prepared by Peter Pengily, Customer
Research & Analysis Leader, Idaho Power Company, in consultation with Lisa D.
Nordstrom, Lead Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO IRRIGATION
PUMPERS ASSOCIATION, INC.'S FIRST DATA REQUEST TO IDAHO POWER COMPANY - 10
REQUEST NO.7: Please provide in electronic format, on an hourly basis, for
the period January 1, 2009 through the most recent month available the following data:
a. Total system input;
b. System input from Company owned generation (stating hydro, coal, and
other generation separately);
c. System input from firm purchases, stating each purchase separately by
source and type of purchase (LF, IF, SF, etc.)
d. The cost of each firm purchase listed in "c" above;
e. System input from non-firm and/or economy purchases, stating each
purchase separately;
f. The cost of each non-firm and/or economy purchase listed in "E" above;
g. System input from exchanges into the system, stating each exchange
separately;
h. System input from Unit purchases;
i. Other system inputs, stating for each "othet' input the type and the source
of the input;
j. System losses;
k. Requirements Wholesale sales (RQ);
i. Long-term firm Wholesale sales (LF), stating each on separately;
m. Intermediate-term firm Wholesale sales (IF), stating each one separately;
n. Short-term Wholesale sales (SF), stating each one separately;
o. Unit sales, Wholesale (LU) or otherwise, stated separately;
p. Non-firm and/or economy Wholesale sales (OS), stated separately;
q. The revenue collected each hour from each non-firm and/or economy
purchased listed in "P" above.
r. Exchanges out of the system, stating each exchange separately;
IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO IRRIGATION
PUMPERS ASSOCIATION, INC.'S FIRST DATA REQLJEST TO IDAHO POWER COMPANY - 11
s. Other system outputs, stating for each "othet' output the type and
recipient of the output;
t. Inadvertent power flows into or out of the system;
u. The power available (at input level) to supply retail load once Wholesale,
Exchange, Wheeling, and Inadvertent has been subtracted;
v. Losses assigned to each retail jurisdiction;
w. Losses assigned to Wholesale sales;
x. Total retail load by jurisdiction;
RESPONSE TO REQUEST NO.7:
a - u. Please see Attachments 1 and 2 and the confidential CD. Because
Attachments 1 and 2 are confidential, Idaho Power wil provide the information only to
parties that sign and return the Protective Agreement in this docket. To use the files
contained on the confidential CD, utilize the drop-down menus found on line 6. For
instance, clicking on the arrow on line 6 of column A wil show the drop-down menu for
system load data. To view the system load data, select "system load" from the menu.
This selection wil bring up the system load data starting in column Z. The specific
responses are identified by the column headings on line 5.
v-x. Please see Attachment 3, Load and Loss Data, on the enclosed non-
confidential CD. Idaho Power utilzes the values in the following table to calculate
losses for the various components of its transmission and distribution system:
Average System Loss Coefficients
System Level
Typical Peak
Demand
Coefficients
Transm iss ion
Distribution Station
Distribution Primary
Distribution Secondary*
1.055
1.065
1.100
1.130
IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO IRRIGATION
PUMPERS ASSOCIATION, INC.'S FIRST DATA REQUEST TO IDAHO POWER COMPANY - 12
System Level
Annual Energy
Coefficients
Transmission 1.035Distribution Station 1 .050Distribution Primary 1 .074Distribution Secondary* 1.109
* Distribution Secondary includes distribution line transformers
The response to this Request was prepared Mark Stokes, Manager of Power
Supply Planning, and Sandra Ward, Accountant ", Idaho Power Company, in
consultation with Lisa D. Nordstrom, Lead Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO IRRIGATION
PUMPERS ASSOCIATION, INC.'S FIRST DATA REQUEST TO IDAHO POWER COMPANY -13
REQUEST NO.8: From January 2005 through the most recent month available,
what was the date and time and magnitude of the monthly system peak?
RESPONSE TO REQUEST NO.8: Please see the Excel file provided on the
enclosed CD.
The response to this Request was prepared by Sandra Ward, Accountant ",
Idaho Power Company, in consultation with Lisa D. Nordstrom, Lead Counsel, Idaho
Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO IRRIGATION
PUMPERS ASSOCIATION, INC.'S FIRST DATA REQUEST TO IDAHO POWER COMPANY - 14
REQUEST NO.9: From January 2005 through the most recent month available,
what was the date and time and magnitude of the monthly system peak that would have
occurred, had there been no curtailment of Residential, Commercial, and/or Irrigation
load?
RESPONSE TO REQUEST NO.9: Please see the below table.
Estimated System Peak
Month Peak DatelTme Absent Demand
Response
January 2005 1/5/057 PM 2,063
February 2005 2117058AM 2,072
March 2005 3/1/058 AM 1,812
April 2005 4/14/058AM 1,796
May 2005 5/28/056 PM 1,863
June 2005 6/21/055 PM 2,644
July 2005 7/21/055 PM 2,965
August 2005 8/9/055 PM 2,849
September 2005 9/8/056 PM 2,394
October 2005 10/5/058AM 1,746
November 2005 11/28/058 AM 2,063
December 2005 12/15/058 AM 2,345
January 2006 1/25/068 AM 2,079
February 2006 2/16/068AM 2,144
March 2006 3/10/069AM 1,946
April 2006 4/6/068AM 1,740
May 2006 5117/067 PM 2,552
June 2006 6/27/066 PM 3,085
July 2006 7/24/066 PM 3,119
August 2006 817066 PM 2,940
September 2006 9/5/066 PM 2,578
October 2006 10/31/068 AM 1,997
November 2006 11/29/06 8 AM 2,226
December 2006 12/18/068 AM 2,318
IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO IRRIGATION
PUMPERS ASSOCIATION, INC.'S FIRST DATA REQUEST TO IDAHO POWER COMPANY -15
January 2007 1/16/078 AM 2,422
February 2007 2/2/078AM 2,268
March 2007*3/1/078 PM 2,023
April 2007 4/30/076 PM 1,937
May 2007 5/31/077 PM 2,484
June 2007 6/28/076 PM 3,063
July 2007 7/13/074 PM 3,193
August 2007 8/1/077 PM 2,936
September 2007 9/3/077 PM 2,695
October 2007 10/31/078AM 1,838
November 2007 11/30/078 AM 2,130
December 2007 12/11/078 AM 2,287
January 2008 1/24/088AM 2,464
February 2008 2I5/088AM 2,270
March 2008 3/3/088AM 2,028
April 2008 4/1/088 AM 1,993
May 2008 5/19/086 PM 2,577
June 2008 6/30/083 PM 3,214
July 2008 7/3/086 PM 3,182
August 2008 817085 PM 3,049
September 2008 9/18/086 PM 2,297
October 2008 10/1/086 PM 2,000
November 2008 11/24/088 AM 1,973
December 2008 12117/088 AM 2,396
January 2009 1/27/098 AM 2,311
February 2009 2/2/098AM 2,160
March 2009 3/11/098AM 2,131
April 2009 4/1/098 AM 1,904
May 2009 5/29/095 PM 2,606
June 2009 6/29/097 PM 2,773
July 2009 7/22/096 PM 3,181
August 2009 8/3/096 PM 2,987
September 2009 9/3/096 PM 2,698
October 2009 10/29/09 8 AM 1,870
Novem ber 2009 11/30/098 AM 1,969
December 2009 12/10/098 AM 2,528
IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO IRRIGATION
PUMPERS ASSOCIATION, INC.'S FIRST DATA REQUEST TO IDAHO POWER COMPANY - 16
January 2010 1/8/108AM 2,215
February 2010 2/22/108AM 2,049
March 2010 3/11/108AM 1,894
April 2010 4/9/108AM 1,807
May 2010 5/17105 PM 1,906
June 2010 6/28/107 PM 2,938
July 2010 7/16/107 PM 3,059
August 2010 8/4/106 PM 2,879
September 2010 9/3/107 PM 2,342
October 2010 1011/106 PM 2,006
November 2010 11/241109 AM 2,149
December 2010 12/301107 PM 2,102
* March 2007 Peak was reported in the FERC Form 1 on Pacifc Time; here it is reported in
Mountain Standard Time.
The response to this Request was prepared by Mary Graesch, Load Research
Leader, Idaho Power Company, in consultation with Lisa D. Nordstrom, Lead Counsel,
Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO IRRIGATION
PUMPERS ASSOCIATION, INC.'S FIRST DATA REQUEST TO IDAHO POWER COMPANY - 17
REQUEST NO. 10: For each month from January 2005 through the most recent
month available, what was the amount of Retail energy used and the amount of
Wholesale energy used? Please indicate how losses are addressed or not addressed
in the above figures.
RESPONSE TO REQUEST NO. 10: Please see the Excel file provided on the
enclosed CD. Losses incurred are not included in either Retail energy biled at the
meter or in the Wholesale energy delivered.
The response to this Request was prepared by Mark Stokes, Manager of Power
Supply Planning, Idaho Power Company, in consultation with Lisa D. Nordstrom, Lead
Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO IRRIGATION
PUMPERS ASSOCIATION, INC.'S FIRST DATA REQUEST TO IDAHO POWER COMPANY - 18
REQUEST NO. 11: During the hour of the monthly peak from January 2008
through the most recent month available, please provide the following:
a. How many megawatts of generation were out of service for planned
maintenance?
b. How much electricity was generated from Company owned hydro?
c. How much electricity was purchased from Company owned thermal
power?
d. How much electricity was purchased from QF suppliers?
e. How much electricity was brought in or sent out through exchanges? How
much (non-QF electricity was purchased and at what price? Please list
each transaction separately, stating name of seller, MWH purchased,
purchase price, and type of purchase (LF, RQ, SF, OS, etc.)?
f. How much electricity was sold off-system and at what price? Please list
each transaction separately, stating name of seller, MWH sold, sale price,
and type of sale (LF, RQ, SF, OS, etc.)?
g. How much load was interrupted via the Irrigation Load Management
program or other similar programs? Please specify each program
separately.
RESPONSE TO REQUEST NO. 11:
a-f. Please see the Excel file provided on the enclosed CD. The request for
the sellets name in lie" above is confidential but wil be made available for review upon
request at Idaho Powets corporate offices. Please contact Doug Jones at 388-2615 or
Camila Victoria at 388-5821 to arrange a time to review the requested materiaL. The
sellets name in response to "f' above is Idaho Power Company.
g. Please see Attachment 3, Dispatch Days 2009 2010, provided by the
Company it its Response to Request NO.6.
IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO IRRIGATION
PUMPERS ASSOCIATION, INC.'S FIRST DATA REQUEST TO IDAHO POWER COMPANY - 19
The response to this Request was prepared by Mark Stokes, Manager of Power
Supply Planning, and Sandra Ward, Accountant II, Idaho Power Company, in
consultation with Lisa D. Nordstrom, Lead Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO IRRIGATION
PUMPERS ASSOCIATION, INC.'S FIRST DATA REQUEST TO IDAHO POWER COMPANY - 20
REQUEST NO. 12: In this case the Company is proposing to put Schedule 23
customers on a variable credit basis where only 40% of the existing rate wil be paid out
as a fixed fee and the other 60% wil be considered variable where, depending upon
usage, 0-60% of the credit wil be issued. What are the Company's plans to provide a
similar fixed/variable credit for Residential and/or Commercial demand response
programs?
RESPONSE TO REQUEST NO. 12: The Company may assess the viability of a
variable pricing model for the AlC Cool Credit program in the future. However, the
incentives for the AlC Cool Credit program are a smaller portion of the overall program
cost and relatively small on a per customer basis. Therefore implementing a variable
incentive model may not be practicaL.
For the FlexPeak Management program, a portion of the energy payment made
to the third-party provider is currently variable, based on the number of events called in
a week and the energy reduction realized during an event. This program is
administered under contract with a third-part provider with a five-year contract which
will expire after the 2013 season. Idaho Power may assess the viabilty of increasing
the variable portion of this program in the future.
The response to this Request was prepared by Peter Pengily, Customer
Research & Analysis Leader, Idaho Power Company, in consultation with Lisa D.
Nordstrom, Lead Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO IRRIGATION
PUMPERS ASSOCIATION, INC.'S FIRST DATA REQUEST TO IDAHO POWER COMPANY - 21
REQUEST NO. 13: IPCo's 2009 DSM Report filed March 15, 2010, at the
bottom of page 8 states:
Next to distributed generation, the company's demand
response programs are the least-cost resource for meeting
summer peak loads over the 20-year IRP planning period.
With respect to this statement, please provide the cost data that supports this statement
by specifically providing the levelized cost (or whatever data the Company used) to
define the 20-year cost of:
a. A single-cycle combustion turbine;
b. Distributed generation (please list size of units annualized);
c. The Irrigation demand response program;
d. The Residential demand response program; and
e. The Commerciallindustrial demand response program.
RESPONSE TO REQUEST NO. 13: The levelized capacity costs for each
resource listed in the 2009 Integrated Resource Plan ("IRP") can be found on page 74
in Figure 6.1. This table includes the dollars per kW/month levelized costs for all
resources, including Distributed Generation, the demand response programs by sector,
and a Simple-Cycle CT - Industrial Frame (170 megawatts ("MW")). It can be seen
from this table that the three demand response programs are listed as least cost
(capacity) resources with the exception of Distributed Generation. Details of these
calculations and assumptions are included in the Company's Response to Request No.
13.a-e.
a. Please see the Supply-Side Resources tab, columns K through R, which
shows the 30 year Capital Costs, Fixed O&M, and Variable O&M tied to the 2009 IRP,
IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO IRRIGATION
PUMPERS ASSOCIATION, INC.'S FIRST DATA REQUEST TO IDAHO POWER COMPANY - 22
of the Excel file provided on the enclosed CD. Assumptions from the 2009 IRP for a
Simple Cycle CT - Industrial Frame (170 MW) are found on page 89 of the IRP,
Appendix C Technical Appendix. See also Figure 6.1 30- Year Levelized Capacity
(Fixed) Costs found on page 74 of the 2009 IRP for a graphical comparison of levelized
capacity costs.
b. Please see the Supply-Side Resources tab, columns A through H, which
shows the 30 year Capital Costs, Fixed O&M, and Variable O&M tied to the 2009 IRP,
of the Excel file provided on the enclosed CD. Assumptions from the 2009 IRP for
Distributed Generation - (15 MW) are found on page 89 of the IRP, Appendix C
Technical Appendix. Please also see Figure 6.1 30- Year Levelized Capacity (Fixed)
Costs found on page 74 of the 2009 IRP for a graphical comparison of levelized
capacity costs. Please note that there are no distinctions in the modeling or calculation
of the costs of the gas or diesel fueled Distributed Generation options.
c. Please see the Demand-Side Resources tab, which is the spreadsheet
source of Table DSM-13 found on page 106 of the 2009 IRP, Appendix C - Technical
Appendix, of the Excel file provided on the enclosed CD. Columns A through E list the
Demand Response Utilty Costs 2010-2019 for each of the demand response programs
offered to the residential, commercial/industrial, and irrigation customer sectors. This
table shows each year's nominal program costs for each sector along with the net-
present-value calculation over the entire 20-year planning horizon. See Table DSM-1
IRP Financials on page 98 of the 2009 IRP, Appendix C - Technical Appendix, for a list
of financial assumptions used for the net-present-value calculations. The net-present-
value of the forecasted 20-year stream of demand reduction is found in the Excel
IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO IRRIGATION
PUMPERS ASSOCIATION, INC.'S FIRST DATA REQUEST TO IDAHO POWER COMPANY - 23
spreadsheet provided on the enclosed CD on the Demand-Side Resources tab under
the title Table DSM-16 Demand Response Cost-Effectiveness Summary, which is also
found on page 107 of the 2009 IRP, Appendix C - Technical Appendix. The data is
labeled in the table as the 20- Year Demand Impact (kW NPV). Please note that the
corresponding column in the original IRP document is mislabeled as "kWh." The
forecasted 20-year impact of the demand response programs by sector is contained in
Table DSM-12, Total Existing and New Demand Response Forecasted Impacts 2010-
2029, is found on page 105 in the 2009 IRP, Appendix C - Technical Appendix. Table
DSM-16 Demand Response Cost-Effectiveness Summary, included in the spreadsheet
provided on the enclosed CD on the Demand-Side Resources tab, column 0, lists the
total levelized costs in dollars per KW year for each sector and the total of all sectors.
Column P shows the levelized cost by sector and total dollars per kW month.
d. Please see Attachment 3, Dispatch Days 2009 2010, provided by the
Company in its Response to Request NO.6.
e. Please see Attachment 3, Dispatch Days 2009 2010, provided by the
Company in its Response to Request NO.6.
The response to this Request was prepared by Peter Pengily, Customer
Research & Analysis Leader, and Mark Stokes, Manager, Power Supply Planning,
Idaho Power Company, in consultation with Lisa D. Nordstrom, Lead Counsel, Idaho
Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO IRRIGATION
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REQUEST NO. 14: Please provide a copy of all data and studies in the
Company's possession that review the actual usage for Residential, Commercial, and
Irrigation demand response customers that demonstrates their usage on day (sic) when
curtailments are not called and the usage on the entire day of those days when
curtailments are called.
RESPONSE TO REQUEST NO. 14: Please see the copies of all known data
and studies which contain actual usage for Residential, Commercial, and Irrigation
demand response customers provided on the enclosed CD. This data shows the usage
on days where demand response was dispatched and days it was not. Please note that
the load data for FlexPeak contains the day of an event and the ten days previous for
hours 11 :00 a.m. to 8:00 p.m.
The response to this Request was prepared by Peter Pengily, Customer
Research & Analysis Leader, Idaho Power Company, in consultation with Lisa D.
Nordstrom, Lead Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO IRRIGATION
PUMPERS ASSOCIATION, INC.'S FIRST DATA REQUEST TO IDAHO POWER COMPANY - 25
REQUEST NO. 15: Are the forecasted load duration curves on Exhibit 1 page 3
based upon normal or 95th percentile loads?
RESPONSE TO REQUEST NO. 15: The forecast load duration curves for the
years 2011 through 2017 shown on page 3 of Exhibit No. 1 to the testimony of Peter
Pengily are based on 70th percentile monthly average loads and 95th percentile peak-
hour loads. These same criteria are used for peak-hour (capacity) planning in the IRP.
The response to this Request was prepared by Thomas A. Noll, Ph.D., Senior
Planning Analyst, Idaho Power Company, in consultation with Lisa D. Nordstrom, Lead
Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO IRRIGATION
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REQUEST NO. 16: Both pages 3 and 4 of Exhibit 1 demonstrate that some of
the data in the forecasted load duration curves are not parallel, i.e. some of the graphs
overlap. Why are some of the load duration curves steeper in the 0-10 hour (highest
hour) timeframe than other years?
RESPONSE TO REQUEST NO. 16: Except for the actual values reported for
2008 and 2009 on page 3, the load duration curves and data shown on pages 3 and 4
of Exhibit No. 1 are planning period forecasts. Idaho Power uses a complex planning
model to create hourly load shapes from the monthly peak and average load forecasts
developed with the Company's long-term planning modeL. The hourly shaping model
uses daily weather forecasts that are the same for the summer months in each year of
the planning period. Even though the weather forecast is the same on July 20 for each
year in the planning period, July 20 falls on different days of the week in different years,
and the day of the week has significant influence on customer load. The point of the
hourly shaping model and the resulting load duration curves is to model the actual
situation that Idaho Power summer load does not always peak on the same calendar
day every summer and the actual distribution of the hourly load varies from year-to-
year. Idaho Power's hourly shaping model captures the variabilty in the load duration
curves and allows Idaho Power to plan resources to address the daily, monthly, and
yearly variability in load.
The response to this Request was prepared by Thomas A. Noll, Ph.D., Senior
Planning Analyst, Idaho Power Company, in consultation with Lisa D. Nordstrom, Lead
Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO IRRIGATION
PUMPERS ASSOCIATION, INC.'S FIRST DATA REQUEST TO IDAHO POWER COMPANY - 27
REQUEST NO. 17: On page 6 lines 4-15 of Mr. Pengily's testimony it is stated
that in 2010 that IPCo enhanced its traditional 2011 IRP analysis. Please provide a
copy of all information associated with this enhancement that lead to "the proposed
Program modifications" that were "a direct result of that review."
RESPONSE TO REQUEST NO. 17: Idaho Power's traditional analysis has
consisted of estimating the demand reduction associated with the program based on
system load data, actual demand enrolled in the program, realization rates from third-
party and in-house studies, and load research data. This information has been provided
in the Company's Response to Request No. 14, including the 2007, 2008, and 2009
Irrigation Peak Rewards reports filed with the Commission. This demand reduction
estimate along with actual and forecast expenses and demand savings were
incorporated into a 20-year cost-effectiveness analysis to determine if the program was
cost-effective. The cost-effectiveness analysis compared the levelized cost per kW of
the program with the levelized cost per kW of a 170 MW simple cycle combustion
turbine. The cost-effectiveness methodology is described in the technical appendices
Idaho Powets Integrated Resource Plans and in the Demand-Side Management 2009
Annual Report; Supplement 1: Cost-effectiveness. The results of this cost-effectiveness
analysis were reported in the Irrigation Peak Rewards reports and the Demand-Side
Management Annual report filed with the Commission.
In 2010, the Company conducted additional analyzes, the results of which are
shown in Exhibit No. 1 of the direct testimony of Peter Pengily. The data that produced
the chart on page 1 is included in the Company's Response to Request NO.6. The data
used to generate page 2 of Exhibit No. 1 is included on the enclosed CD as Attachment
IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO IRRIGATION
PUMPERS ASSOCIATION, INC.'S FIRST DATA REQUEST TO IDAHO POWER COMPANY - 28
1, Forecast Peak day 2011. The data that was used to produce the chart on page 3 of
Exhibit No. 1 in is included on the enclosed CD as Attachment 2, LoadDurationCurves
2011_2014. The data supporting the chart on page 4 of Exhibit NO.1 is included is
included on the enclosed CD as Attachments 3 and 4,2010 11 15 Load and Resource
Balance for DR Calculations and 2010 11_15 2011 IRP Demand Response Targets.
Additionally, included as Attachment 5, 2010 11_16 SCCT vs Demand Response
Program Cost Updated, on the enclosed CD is a graph used to visualize how the
program compares to a simple cycle combustion peaker on a megawatt-hour basis.
The response to this Request was prepared by Peter Pengily, Customer
Research & Analysis Leader, Idaho Power Company, in consultation with Lisa D.
Nordstrom, Lead Counsel, Idaho Power Company.
DATED at Boise, Idaho, this 28th day of January 2011.
~N~òlkrrbm
Attorney for Idaho Power Company
IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO IRRIGATION
PUMPERS ASSOCIATION, INC.'S FIRST DATA REQUEST TO IDAHO POWER COMPANY - 29
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this 28th day of January 2011 I served a true and
correct copy of IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO
IRRIGATION PUMPERS ASSOCIATION, INC.'S FIRST DATA REQUEST TO IDAHO
POWER COMPANY upon the following named parties by the method indicated below,
and addressed to the following:
Commission Staff
Weldon B. Stutzman
Deputy Attorney General
Idaho Public Utiities Commission
472 West Washington
P.O. Box 83720
Boise, Idaho 83720-0074
Idaho Irrigation Pumpers
Association, Inc.
Eric L. Olsen
RACINE, OLSON, NYE, BUDGE &
BAILEY, CHARTERED
201 East Center
P.O. Box 1391
Pocatello, Idaho 83204-1391
Anthony Yankel
Yankel & Associates, Inc.
29814 Lake Road
Bay Vilage, Ohio 44140
-l Hand Delivered
U.S. Mail
_ Overnight Mail
FAX
-l Email Weldon.Stutzman(âpuc.idaho.gov
Hand Delivered
-2U.S. Mail
_ Overnight Mail
FAX
-l Email elo(âracinelaw.net
Hand Delivered
-2U.S. Mail
_ Overnight Mail
FAX
-2 Email tony(gyankel.net
cL..d2 ::~
Lisa D. Nordstro
IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO IRRIGATION
PUMPERS ASSOCIATION, INC.'S FIRST DATA REQUEST TO IDAHO POWER COMPANY - 30