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Home My WebLink About20111115IPC to ICL,NWEC,SRA 1-5.pdfHIDA~PO~ An IDACORP Company JASON B. WILLIAMS Corporate Counsel jwilliamsl.idahopower.com November 15, 2011 VIA HAND DELIVERY Jean D. Jewell, Secretary Idaho Public Utilties Commission 472 West Washington Street Boise, Idaho 83702 Re: Case No. IPC-E-11-08 General Rate Case Dear Ms. Jewell: Enclosed for filing are an original and one (1) copy of Idaho Power Company's Response to the First Production Request ofthe Idaho Conservation League, N.W. Energy Coalition, and Snake River Alliance to Idaho Power in the above matter. t , JBW:kkt Enclosures LISA D. NORDSTROM (ISB No. 5733) DONOVAN E. WALKER (ISB No. 5921) JASON B. WILLIAMS (ISB No. 8718) Idaho Power Company 1221 West Idaho Street (83702) P.O. Box 70 Boise, Idaho 83707 Telephone: (208) 388-5825 Facsimile: (208) 388-6936 Inordstrom(âidahopower.com dwalker(âidahopower.com jwilliams(âidahopower.com Attorneys for Idaho Power Company 0\, i: r,i: Di i;'"".. ¡. -mil ~lO\1 I c: p'¡"~ 4: 20L.Ui Ii , v BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION IN THE MAnER OF THE APPLICATION ) OF IDAHO POWER COMPANY FOR ) AUTHORITY TO INCREASE ITS RATES ) AND CHARGES FOR ELECTRIC )SERVICE IN IDAHO. ) ) ) ) ) ) ) CASE NO. IPC-E-11-08 IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE IDAHO CONSERVATION LEAGUE, N.W. ENERGY COALITION, AND SNAKE RIVER ALLIANCE TO IDAHO POWER COMES NOW, Idaho Power Company ("Idaho Powet' or "Company"), and in response to the First Production Request of the Idaho Conservation League, N.W. Energy Coalition, and Snake River Allance to Idaho Power dated October 25, 2011, herewith submits the following information: IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE IDAHO CONSERVATION LEAGUE, N.W. ENERGY COALITION, AND SNAKE RIVER ALLIANCE TO IDAHO POWER - 1 REQUEST NO.1: Please provide the dollar amount Idaho Power has spent each year on evaluation, measurement and verification of all Demand Side Management programs for 2008, 2009, and 2010. Please include the total costs for both internal and external reviews as well as labor, overhead, materials, and any other expenses. RESPONSE TO REQUEST NO.1: In 2008, Idaho Power spent $86,856 on third-party evaluations for its demand-side management ("DSM") programs. In 2009, the Company spent $206,483 on third-party evaluations for its DSM programs, plus an additional $139,034 on an energy effciency potential study. In 2010, as stated on page 11 of the Demand-Side Management 2010 Annual Report, the Company spent $293,000 on third-part evaluations of its DSM programs. Only evaluation expenses for studies conducted by third parties are directly tracked and accounted for in program expenses. The response to this Request was prepared by Pete Pengily, Customer Research & Analysis Leader, Idaho Power Company, in consultation with Jason B. Wiliams, Corporate Counsel, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE IDAHO CONSERVATION LEAGUE, N.W. ENERGY COALITION, AND SNAKE RIVER ALLIANCE TO IDAHO POWER - 2 REQUEST NO.2: Please provide Idaho Power's most recently available forecast of spending for evaluation, measurement and verification of all Demand Side Management programs for 2011 and 2012. RESPONSE TO REQUEST NO.2: In 2011, Idaho Power forecasts that it wil spend approximately $438,000 on third-party program evaluations. In 2012, the Company forecasts that it wil spend approximately $380,000 on third-party program evaluations. The response to this Request was prepared by Pete Pengilly, Customer Research & Analysis Leader, Idaho Power Company, in consultation with Jason B. Willams, Corporate Counsel, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE IDAHO CONSERVATION LEAGUE, N.W. ENERGY COALITION, AND SNAKE RIVER ALLIANCE TO IDAHO POWER - 3 REQUEST NO.3: Please answer the following regarding Company's evaluation plan for 2010-2012 found on pages 4-6 of Supplement 2 of Idaho Powets 2010 Demand Side Management Annual Report. a. Does Idaho Power stil intend to follow the plan as described? b. Would a reduction in the Energy Effciency Rider level change this evaluation plan? If the answer is yes, please describe how so. If the answer is no, please describe how the Company intends to adjust program budgets to maintain the evaluation plan while stil acquiring all cost effective energy efficiency. RESPONSE TO REQUEST NO.3: a. Throughout 2010, Idaho Power made minor revisions to its evaluation plan. In 2011, Idaho Power has made very few revisions to its plan and those revisions served to broaden the scope of the evaluations. The Company does not plan any major changes to the 2012 plan, but if any are anticipated, they wil be included in the Company's Demand-Side Management 2011 Annual Report. Program evaluation is an important facet of Idaho Power's DSM operational activities. Idaho Power has increased the frequency and the breadth of evaluations since the signing of the Memorandum of Understanding for Prudency Determination of DSM Expenditures ("MOU"), which specifies the Idaho Public Utilties Commission ("Commission") Staff's expectations of utilities' evaluations. Idaho Power relies on evaluations by third-party contractors, internal analyses, and regional studies to ensure the ongoing cost-effectiveness and overall effectiveness of programs through validation of program processes, energy savings, and demand reduction. The results of Idaho Powets evaluation efforts are used to enhance or initiate program changes. Annually, IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE IDAHO CONSERVATION LEAGUE, N.W. ENERGY COALITION, AND SNAKE RIVER ALLIANCE TO IDAHO POWER - 4 Idaho Power publishes its evaluation plan for three years in the Demand-Side Management Annual Report, Supplement 2. As stated in Idaho Powets Demand-Side Management 2010 Annual Report, on page 13 under "Program Evaluation": "Although the evaluation plan is expected to be used for scheduling evaluations, the timing of specific program evaluations wil be based on considerations of program evaluation needs, and other relevant regional studies." b. No. The level of Idaho Energy Efficiency Rider ("Ridet') funding does not and has not determined Idaho Powets level of spending and/or evaluation of its DSM efforts. The response to this Request was prepared by Pete Pengily, Customer Research & Analysis Leader, Idaho Power Company, in consultation with Jason B. Wiliams, Corporate Counsel, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE IDAHO CONSERVATION LEAGUE, N.W. ENERGY COALITION, AND SNAKE RIVER ALLIANCE TO IDAHO POWER - 5 REQUEST NO.4: Page 127 of Idaho Power's 2010 Demand Side Management Annual Report indicates the Idaho Energy Effciency Rider was underfunded by $17,592,938. In Order No. 32331, the Commission found all 2010 DSM spending was prudent. a. What is the most recent balance in the Idaho Energy Efficiency Rider account for expenses incurred in 2010 but yet to be recovered by the Company? b. If ratepayers owe the Company for prudently incurred energy efficiency expenses does the Company collect an interest charge on this amount? If so, how much? c. If ratepayers owe the Company money for prudently incurred energy efficiency expenses does the Company plan to recover these funds in a single year or over several years? RESPONSE TO REQUEST NO.4: a. As of the end of 2010, the Idaho Energy Efficiency Rider account unfunded balance was $17,592,938. This balance was considered prudently incurred by the Commission in Order No. 32113. Through Case No. IPC-E-10-27, Order No. 32245, Idaho Power was allowed to place $10 millon of this $17 millon of the Idaho Energy Efficiency Rider account unfunded balance from 2010 into the 2011 Power Cost Adjustment ("PCA") for recovery. The amount included in the PCA is anticipated to be fully recovered by the end of May 2012. The remaining prudently incurred Rider expenses from 2010 of $7,592,938 wil be recovered by current year Rider funding. IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE IDAHO CONSERVATION LEAGUE, N.W. ENERGY COALITION, AND SNAKE RIVER ALLIANCE TO IDAHO POWER - 6 b. Idaho Power is currently allowed to collect or pay 1 percent annual interest on the balance of the Energy Effciency account depending on whether it has a positive or negative balance. Under Commission Order No. 32109, Idaho Power is directed to collect and/or pay 1 percent annual interest on all customer deposits in 2011. c. Although timely cost recovery for DSM expenses is one of Idaho Powets goals, as a practical matter, this is somewhat difficult. The Company's ultimate goal with Rider funding is to match revenue with expenses over time. However, revenues and expenses wil not match in a single year. The response to this Request was prepared by Pete Pengily, Customer Research & Analysis Leader, Idaho Power Company, in consultation with Jason B. Williams, Corporate Counsel, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE IDAHO CONSERVATION LEAGUE, N.W. ENERGY COALITION, AND SNAKE RIVER ALLIANCE TO IDAHO POWER - 7 REQUEST NO.5: Idaho Powets 2011 Integrated Resource Plan forecasts increasing energy efficiency acquisitions from both existing and new programs or measures. Please describe the method for quantifying these projections. RESPONSE TO REQUEST NO.5: Idaho Powets methods of projecting future energy efficiency acquisitions from both existing and new measures are explained in detail on pages 39-41 of the Company's 2011 Integrated Resource Plan. Copies of pages 39-41 are attached. The response to this Request was prepared by Pete Pengily, Customer Research & Analysis Leader, Idaho Power Company, in consultation with Jason B. Williams, Corporate Counsel, Idaho Power Company. DATED at Boise, Idaho, this 15th day of November 2~ 1. IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE IDAHO CONSERVATION LEAGUE, N.W. ENERGY COALITION, AND SNAKE RIVER ALLIANCE TO IDAHO POWER - 8 CERTIFICATE OF SERVICE I HEREBY CERTIFY that on this 15th day of November 2011 I served a true and correct copy of IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE IDAHO CONSERVATION LEAGUE, N.W. ENERGY COALITION, AND SNAKE RIVER ALLIANCE TO IDAHO POWER upon the following named parties by the method indicated below, and addressed to the following: Commission Staff Donald L. Howell, II Karl T. Klein Deputy Attorneys General Idaho Public Utilties Commission 472 West Washington (83702) P.O. Box 83720 Boise, Idaho 83720-0074 Hand Delivered U.S. Mail _ Overnight Mail FAX -l Email Don.Howell(âpuc.idaho.gov Karl. Klein(âpuc. idaho.gov Industrial Customers of Idaho Power Peter J. Richardson Gregory M. Adams RICHARDSON & O'LEARY, PLLC 515 North 27th Street (83702) P.O. Box 7218 Boise, Idaho 83707 Hand Delivered U.S. Mail _ Overnight Mail FAX -l Email peter(ârichardsonandoleary.com greg(arichardsonandoleary.com Dr. Don Reading Ben Johnson Associates, Inc. 6070 Hil Road Boise, Idaho 83703 Hand Delivered U.S. Mail _ Overnight Mail FAX -l Email dr(abenjohnsonassociates.com 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 Hand Delivered U.S. Mail _ Overnight Mail FAX -l Email elo(aracinelaw.net Anthony Yankel 29814 Lake Road Bay Vilage, Ohio 44140 Hand Delivered U.S. Mail _ Overnight Mail FAX -l Email tony(ayankel.net IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE IDAHO CONSERVATION LEAGUE, N.W. ENERGY COALITION, AND SNAKE RIVER ALLIANCE TO IDAHO POWER - 9 The Kroger Co. Kurt J. Boehm BOEHM, KURTZ & LOWRY 36 East Seventh Street, Suite 1510 Cincinnati, Ohio 45202 Hand Delivered U.S. Mail _ Overnight Mail FAX -l Email kboehm(aBKLlawfirm.com jrh(abattfisher.com Kevin Higgins Energy Strategies, LLC 215 South State Street, Suite 200 Salt Lake City, Utah 84111 Hand Delivered U.S. Mail _ Overnight Mail FAX -l Email khiggins(aenergystrat.com Micron Technology, Inc. MaryV. York HOLLAND & HART, LLP 101 South Capital Boulevard, Suite 1400 Boise, Idaho 83702 Hand Delivered U.S. Mail _ Overnight Mail FAX -l Email myork(ahollandhart.com tnelson(aholland hart. com madavidson(aholland hart. com fschmidt(ahollandhart.com Inbuchanan(aholland hart. com Richard E. Malmgren Senior Assistant General Counsel Micron Technology, Inc. 800 South Federal Way Boise, Idaho 83716 Hand Delivered U.S. Mail _ Overnight Mail FAX -l Email remalmgren(amicron.com The United States Department of Energy Arthur Perry Bruder, Attorney-Advisor United States Department of Energy 1000 Independence Avenue SW Washington, DC 20585 Hand Delivered U.S. Mail _ Overnight Mail FAX -l Email Arthur.bruder(ahq.doe.gov Steven. po rter(ahq . doe.gov Dwight D. Etheridge Exeter Associates, Inc. 10480 Little Patuxent Parkway, Suite 300 Columbia, Maryland 21044 Hand Delivered U.S. Mail _ Overnight Mail FAX -l Email detheridge(aexeterassociates.com IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE IDAHO CONSERVATION LEAGUE, N.W. ENERGY COALITION, AND SNAKE RIVER ALLIANCE TO IDAHO POWER - 10 Community Action Partnership Association of Idaho Brad M. Purdy Attorney at Law 2019 North 1 ih Street Boise, Idaho 83702 Hand Delivered U.S. Mail _ Overnight Mail FAX -l Email bmpurdy(ahotmail.com Idaho Conservation League Benjamin J. Otto Idaho Conservation League 710 North Sixth Street (83702) P.O. Box 844 Boise, Idaho 83701 Hand Delivered U.S. Mail _ Overnight Mail FAX -l Email botto(aidahoconservation.org Snake River Allance Ken Miler Snake River Allance P.O. Box 1731 Boise, Idaho 83701 Hand Delivered U.S. Mail _ Overnight Mail FAX -l Email kmiller(asnakeriveralliance.org NW Energy Coalition Nancy Hirsh, Policy Director NW Energy Coalition 811 First Avenue, Suite 305 Seattle, Washington 98104 Hand Delivered U.S. Mail _ Overnight Mail FAX -l Email nancy(anwenergy.org Hoku Materials, Inc. Dean J. Miler McDEVln & MILLER LLP 420 East Bannock (83702) P.O. Box 2564 Boise, Idaho 83701 Hand Delivered U.S. Mail -- Overnight Mail FAX -l Email joe(amcdevitt-miler.com heather(amcdevitt-miller.com Scott Paul, CEO Hoku Materials, Inc. One Hoku Way Pocatello, Idaho 83204 Hand Delivered U.S. Mail _ Overnight Mail FAX -l Email spaul(ahokucorp.oom \. IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE IDAHO CONSERVATION LEAGUE, N.W. ENERGY COALITION, AND SNAKE RIVER ALLIANCE TO IDAHO POWER - 11 BEFORE THE IDAHO PUBLIC UTiliTIES COMMISSION CASE NO. IPC-E-11-08 IDAHO POWER COMPANY RESPONSE TO REQUEST NO.5 Idaho Power Company 4. Demnd-Side Resources Tabl 4.1 Eney effcienc curren pofolio forsted Impact (2011-2030) 2015 (aM 20 (aM 205 (a IndustraJ................................................................ 23 46 61Irrgation .................................................................. 5 8 11Commerial.............................................................. 30 60 80Resntil............................................................... 11 20 26Totl......................................................................... 69 133 178 203O(8MW 66 11 86 28 191 Table 4.2 shows the forecast cost-effectiveness of the curent portfollo of energy efficiency program. The table shows the net-present-value anys of the 20-year forecat of utiity costs, resource costs, and avoided energy. Utity costs are the costs to adminiser the energ effciency progam, while tota resurce costs account for both th utility costs and the customer investment in effciency technlogies and measures offered though the progr. Utility costs and total resurce costs were estimated based on 2010 prom performance for industrial. commercia, and residenti clases and a the-year average peormance for irrgation to allow for anual fluctuations between custom- and menu-drven irgation effciency. Avoided energy is the benefit of the progrs caculed by valuig energy savings againt the avoided generation costs of Idaho Power's existing portfolio of generation resources. Table 4.2 Existing enery effciency portolio cost-eectiveness sumary 2030 Loimp (aM Indtt 66 Irrga 11 Comeia 86 Reidetil 28Totl 191 'Net pr value (NPV Utlity Cots (2YelU NPV") $49,398,58 $14,229.458 $6.885,631 $60,023,978 $184,537,652 Ree Costs (Zo-Yea NPV $96,635,80 $38,51,98 $119,96.128 $103.519,281 $358,773,20 Av EneCo (ZV..NPV $257,70.824 $43,667,373 $335.20.357 $181.086,911 $817,687,485 TotlTot ReRe CoUtHty COst: Uty Co: LøIzBø Løvllzed BefttIos CosRao Co (SWh) Ra (S) 5.2 $0.015 2.7 10.02 3.1 $0.023 1.1 $0.061 5.5 $0.014 2.8 $0.027 3.0 $0.040 1.7 10.06U $0.019 2. SO.G The value of avoided energy over the 20-year investment in the energy effciency meaures was more th twice the tota resource cost when comparig beefits and costs. This resulted in an overal benefit cost ratio of 2.3. The levelid cost to reduce energy demand by 191 aM is 3.6 cents per kWh from a total reource cost perspecive. Figur 6.9 in Chapter 6 compare ener effciency program costs with Idaho Power's other supply-side resouce options from an energy perspective. New Energy Efficiency Resources Dug each IR plang period. Idaho Power use varous resoures, includig exstig portfolio progra expaion, new progam development. potential studies, Nortwest Power and Consrvation Council (NCC) research, and Idaho Power's Energy Efficiency Advisory Group (BEAG), to determe how future energy effciency and demand response programs can fulfll futue resource nee. New energy effciency opportties ar evaluated through a cost-effectivenes analys similar to the existig program. Forecastig assmptions for new residenti effciency for the 2011 IR were aided by the planing model that was developed by Nexant Inc., from the 2009 Deman Side Management Potential Study. Along with identifyig new opportunities for energy effciency it is alo importat to identi th baers that may face new pro measures and exanion. One challenge the company wil contiue 20111RP Page 39 4. Demand-Side Resrces Idaho Pow Copany to face going forward is to increase the unertag of beviors and decisons tht residential customer mae in regards to energy effciency investmts an prviding the corrt level of incentive to motivate them while mataiing cost-effectivenes. Much of the expansion to residential programs analyzed for the 2011 IRP include measurs reuig increased customer investments, such as improved weatherition in electrc home and multi-family housg. It wil beome increasingly important to understad the purchang decisions of prior pacipants and contiue forwar with Idaho Power's efforts of tageted marketg and demographic analys to work to overcome customers' investment barers. Ongoin process evaluations of energy effciency programs wil als contiue to be an important source of inormation for understanding customer paticipation in programs and for developing strategies to incrase participation and progr delivery. Examples of pat proes evaluations for energy effciency progrms can be found in th Demand-Side Management 2010 Annual Report Supplement 2: Evaluation. Industrial Efficiency Efficiency projects, though the Custom Effciency proam, which provides effciency projects to large commercal and industral customers continues to exceed expectations and has perormed wel since the prgr began providing incentives in 2004. Projects can include any combintion of apprved custom meas an proces improvements tht show energy effciency enhacements. Some of th most common projec include measre, such as higher-effciency lightig, fan, compre air, and pumps. Progrm chges, including moving some smer lightig projects of less th 100,000 anual kWh of savings to other progr, wil allow increased capacity for more cutom projects over the next few years. This wil lead to an increased expansion of 13 aMW over the 20-year IR planning horizon. The increased effciency wil cost approxiately 2.6 cents per kWh. Commercial Effciency Progr chges in the commercial and industral effciency program in 2011 wi shif some lightig projects into the Eay Upgrdes prescriptive progr tht previouly would have pad though the Custom Etciency program. These potential savigs wer not accounted for in the original commerc progr portfolio forecast and wi result in an additonal 6.6 aM of average demand reduction potentia over the IR planng horion. Residential Efficiency New residential effciency includes expanded weatherization measures identifed in th Idaho Power Demand-Side Management Potential Study, published in 2009, along with growth in incentives for heat pumps for electrcaly heated homes, an expaion of extig programs into the multi-family sector. Durig 2011 and 2012. plas ar being made to add additiona weathertion measures to Idaho Power's Home Improvement Program, which curently provides incentives for incrasing levels of attic insulation. The additional measurs ar also expected to be made avaiable to multi-famy housing an wil focus on windows, iniltrtion, and HVAC duct sealng. These program additions for electricaly heated homes ar forecasted to add 20.1 aMW of savings to th progrm over the IR planmg horizon. Increased incentives for air-source heat pumps in 2011 wil encourage customers to trantion from electric, forced-air furaces and wil add 0.3 aM of average demand reduction to the progr. Weatherition Solutions for Eligible Customers, a weatherition program for income-qualed customer, wil be expanded to eastero Idaho in 2011. Idaho Power forecasts the new tageted area wil provide 2 aM of increas progrm reduction over th IR plain horion. Page 40 20111RP Idaho Power Company 4. Demand-Side Resurces Table 4.3 shows the forecat combJn contrbution in reduced average consumption over the IR plang horizn. In 2015. the new and expaded ener effciency prog wi reuce average loa by 13 aMW; in 2020, average loads will be reduced by 25 aMW. The fu 20-ye capacity of the program additions and changes is 42 aM of average dema reuction. Table 4.3 New enery efcienc poolio forste Impac (211-2030) 2015 (aM 20 (a 205 (arM7 10 122 5 64 10 1613 25 3& Indutral.... .... .... ......... ..................... .... ........... ..... ...... Com.merclal "'......................."'......;,.....¡,...t..."..j¡",...,.......~.....;¡..."................. Reidential............................................................... Tot.......................................................................... 2030(a 13 7 23 42 Table 4.4 presents a summar of the cot and cost-effectivenes of new energy effciency efforts. The overall benefit/cost ratio for al new energy efficiency measurs is 3.2 at a levelized tota resurce cost of 5.1 cents pe kWh. Addition detais on anua cots and benefits ca be found in Appedix C- Technical Appedix. Table 4.4 New eney efciency poio cost.efvenes summary IndulralCoinReldl Tot 20Lo..(l 13 7 23 42 R8 Co (20V..NPV S20,135,88t $8607,815 $6,027,549 .7.771,250 UdBtyCo(2.V..NP $10,293,124 54,468.872 135.58870_3..,8 Demand Response Resources TotlTot R8R8 CoAv En UdIl CO UIlty CO UvCo B8t Le11Z Be Co(2Veer NPV Rao Co (S) Ra (t) S56,34.905 5.4 SO.013 2.8 S0.26 $25,770,482 5. $0.013 3.0 $0.025 $228,851,04 6.4 S0.45 3. $008 $310.65 8. $002 3. SO.D1 The goal of demand respons program at Idaho Power is to reuce sumer peak load durng periods of extremely high demad and minmie or delay the need to build new supply-side reurces. Demad reponse programs were fit implemented in summer 2004 when a 6.1-MW peak-hou load reuction was measured. Idao Power's demand response portfolio ha grown sice that tie. and 330 MW of pek-hour load reduction ha ben tageted for sumer 20 1 L Thr pros 1) AlC Cool Creit, 2) Irrigation Peak Rewards, and 3) FlexPeak Maagement allow residentil. irgation, commeria, and industral customers to paticipate in potenti peak-hour load reuction effort. A complete description of the demad response proams can be foud in Appendix .Band-Side Management 2010 Annual Reort. An anys that focusd on the optimal level of demand response resources along with the costs an the most effective method of utilization was conducted as pat of the 2011 IR. The conclusons drwn from th analysis were tht 1) ther is a defied opti amount of demand reponse for Idaho Power's An Idaho Power customer reprntve discusses the Irriga Peak Rewards pram wi 8 farmer. 20111RP Page 41