20130221IPC to Staff 1-10,14,15, Etc.pdf

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JULIA A. HILTON
Corporate Counsel J )
jhilton(idahoDower.com JTILIT!ES UJMMlSSIO:
February 21, 2013
VIA HAND DELIVERY
Jean D. Jewell, Secretary
Idaho Public Utilities Commission
472 West Washington Street
Boise, Idaho 83702
Re: Case No. IPC-E-12-29
Temporary Suspension of Demand Response Programs - Idaho Power
Company's Responses to the Commission Staff's First Production Request
Nos. 1-10, 14, 15, 18-21, 23, 24, and 26-33
Dear Ms. Jewell:
Enclosed for filing in the above matter are an original and three (3) copies of Idaho
Power Company's responses to the Commission Staff's First Production Request Nos. 1-
10, 14, 15, 18-21, 23, 24, and 26-33. Also enclosed is an original and three (3) copies of
Idaho Power Company's confidential responses to the Commission Staff's First
Production Request Nos. 8, 9,21,28, and 33.
In addition, enclosed are four (4) copies of the non-confidential disk and four (4)
copies of a confidential disk containing data responsive to Staff's Request. Please handle
the confidential information in accordance with the Protective Agreement executed in this
matter.
Very truly yours,
Julia A. Hilton
JAH :evp
Enclosures
1221 W. Idaho St. (83702)
P.O. Box 70
Boise, ID 83707
JULIA A. HILTON (ISB No. 7740) RECEiT
LISA D. NORDSTROM (ISB No. 5733)
Idaho Power Company 21113 FEB 2 i P1 1: 53
1221 West Idaho Street (83702)
P.O.Box 70 U711 I 4 I ,ti Boise, Idaho 83707
Telephone: [phone]
Facsimile: [phone]
ihiItoncidahopower.com
Inordstromidahopower.com
Attorneys for Idaho Power Company
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION
OF IDAHO POWER COMPANY FOR
AUTHORITY TO TEMPORARILY
SUSPEND IT'S NC COOL CREDIT AND
IRRIGATION PEAK REWARDS
DEMAND RESPONSE PROGRAMS.
CASE NO. IPC-E-12-29
IDAHO POWER COMPANY'S
RESPONSES TO THE
COMMISSION STAFF'S FIRST
PRODUCTION REQUEST NOS. 1-
10,14,15,18-21,23,24, AND 26-33
COMES NOW, Idaho Power Company ("Idaho Power" or "Company"), and in
response to the First Production Request Nos. 1-10, 14, 15, 18-21, 23, 24, and 26-33 of
the Commission Staff to Idaho Power Company dated January 31, 2013, herewith
submits the following information:
IDAHO POWER COMPANY'S RESPONSES TO THE COMMISSION STAFF'S
FIRST PRODUCTION REQUEST NOS. 1-10, 14, 15, 18-21, 23, 24, AND 26-33 - 1
REQUEST NO. 1: Please identify and provide the peak hour load for each year
from 2004 through 2012.
RESPONSE TO REQUEST NO. 1: Please see the Excel file provided on the
non-confidential CD that shows the peak load and the hour of the peak load for each
year from 2004 through 2012.
The response to this Request was prepared under the supervision of Theresa
Drake, Customer Relations and Energy Efficiency Manager, Idaho Power Company in
consultation with Lisa D. Nordstrom, Lead Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSES TO THE COMMISSION STAFF'S
FIRST PRODUCTION REQUEST NOS. 1-10, 14, 15, 18-21, 23, 24, AND 26-33-2
REQUEST NO. 2: For each IRP from 2002 to present, please indicate the
amount of peak-hour reduction the Company assumed each Demand Response (DR)
program contributes during the planning period.
RESPONSE TO REQUEST NO. 2:
2002 IRP - No demand response was included. Demand response was identified as
"targeted demand-side management" and mentioned as a possible resource on pages
47 and 63.
2004 IRP - Demand response was discussed on pages 25 and 26 and approximately
76 MW of demand response was included in the Near-Term Action Plan on pages 86
and 87.
2006 IRP - Demand response was mentioned on page 65. Demand response was
estimated to be approximately 100 megawatt ("MW") based on the tables in Appendix 0
on pages 70 and 71 and the following calculations:
Calculations: 190 peak MW (all programs, page 71)
minus 90 a MW on peak (energy efficiency programs, page 70)
equals approximately 100 MW (demand response)
2009 IRP - 367 MW (Table 4.4, page 45)
2011 IRP —351 MW (Table 4.5, page 42)
The response to this Request was prepared by M. Mark Stokes, Director of
Water and Resource Planning, Idaho Power Company, in consultation with Lisa D.
Nordstrom, Lead Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSES TO THE COMMISSION STAFF'S
FIRST PRODUCTION REQUEST NOS. 1-10, 14, 15, 18-21, 23, 24, AND 26-33-3
REQUEST NO. 3: Please provide the verified level of DR reduction for each
peak hour identified in Production Request No. I by program.
RESPONSE TO REQUEST NO. 3: Please see the Excel file provided on the
non-confidential CD that shows the peak reduction from DR for each hour identified by
program.
Idaho Power verifies the load reduction achieved by demand response in several
ways. For FlexPeak Management, electricity use is measured at the participant's meter
in five minute intervals. The electricity use is compared to a calculated baseline to
determine the actual reduction. The load reduction achieved by the FlexPeak
Management program is described in detail in the FlexPeak Management annual report
which is filed annually with the Idaho Public Utilities Commission ("Commission") and
included in Idaho Power's Demand-Side Management Annual Report, Supplement 2:
Evaluation.
For Irrigation Peak Rewards, realization rates are used to estimate the load
reduction for most participants. The original derivation of these realization rates was
established under contract with a third-party evaluator. The company describes these
estimates in each of its Irrigation Peak Rewards Program Reports filed with the
Commission in December of 2007-2009 and included in Idaho Power's Demand-Side
Management Annual Report, Supplement 2: Evaluation, in 2009, 2010, and 2011. The
realization rates derived for these annual reports is the source of the Company's I
reported actual and potential load reduction levels.
The load reduction estimates for the NC Cool Credit Program are based on
evaluations conducted under contract with third-party vendors in 2003, 2004, 2005,
IDAHO POWER COMPANY'S RESPONSES TO THE COMMISSION STAFF'S
FIRST PRODUCTION REQUEST NOS. 1-10, 14, 15, 18-21, 23, 24, AND 26-33-4
2006, 2009, 2011, and 2012. The information from the 2012 study is the most reliable
because the load reduction estimates are based on a census of the participants' AMI
hourly usage data correlated with a sample of participants' air-conditioner compressor
run-time data evaluated by a third-party vendor. The 2012 research report conducted
by a third-party vendor will be included in the Demand-Side Management 2012 Annual
Report, Supplement 2: Evaluation.
Beyond the estimates and evaluations done on individual programs, the total
load reduction from demand response programs can be seen in system load graphs.
Idaho Power checks the reasonableness of the level of demand reduction by examining
these graphs.
The response to this Request was prepared under the supervision of Theresa
Drake, Customer Relations and Energy Efficiency Manager, Idaho Power Company, in
consultation with Lisa D. Nordstrom, Lead Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSES TO THE COMMISSION STAFF'S
FIRST PRODUCTION REQUEST NOS. 1-10, 14, 15, 18-21, 23, 24, AND 26-33-5
REQUEST NO. 4: Please indicate the level of transmission capacity on the
Company's system available for import after accounting for market purchases during the
peak hours identified in Production Request No. 1.
RESPONSE TO REQUEST NO. 4: There was no firm available transmission
capacity on Idaho Power's system during the peak load hours identified in Staffs
Production Request No. 1. The non-firm available transmission capacity is reflected in
the Excel file provided on the non-confidential CD.
The response to this Request was prepared by Tessia Park, Load Serving
Operations Director, Idaho Power Company, in consultation with Lisa D. Nordstrom,
Lead Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSES TO THE COMMISSION STAFF'S
FIRST PRODUCTION REQUEST NOS. 1-10, 14, 15, 18-21, 23, 24, AND 26-33 -6
REQUEST NO. 5: For each year from 2004 through 2012:
a.Please provide the dates and time periods a DR curtailment event
occurred by program.
b.Please provide the level of verified DR curtailment by program for each
event.
C. Please provide the level of 'opt-outs' for each event and by each DR
program.
d. Please indicate how each event restricted the ability to call the subsequent
event.
RESPONSE TO REQUEST NO. 5:
a.Please see the confidential Excel file (Attachment 1) provided on the
confidential CD. The confidential CD will be provided to those parties that have
executed the Protective Agreement in this proceeding.
b. Please see the confidential Excel file (Attachment 1) provided on the
confidential CD. The confidential CD will be provided to those parties that have
executed the Protective Agreement in this proceeding.
C. Customers are only able to opt-out of the A/C Cool Credit program or the
Irrigation Peak Rewards program. For the NC Cool Credit program the opt-outs for
each event are listed in the Excel file (Attachment 2) provided on the non-confidential
CD. Note that as defined in the Rate Schedule 81 a participant can-opt out for one day
per month during the Air Conditioning Season by notifying the Company in advance. As
such the opt-out dates may not coincide with cycling dates because the participants do
not know in advance when the Company will call the program.
IDAHO POWER COMPANY'S RESPONSES TO THE COMMISSION STAFF'S
FIRST PRODUCTION REQUEST NOS. 1-10, 14, 15, 18-21, 23, 24, AND 26-33-7
For the Irrigation Peak Rewards program for the years 2004 through 2008 the
Company had only the Timer Options so if a customer opted out, they opted out of the
program altogether. The opt-outs for 2009 through 2011 are included in the Excel file
(Attachment 3) provided on the non-confidential CD.
d. No event restricted the ability to call the subsequent event.
The response to this Request was prepared under the supervision of Theresa
Drake, Customer Relations and Energy Efficiency Manager, Idaho Power Company, in
consultation with Lisa D. Nordstrom, Lead Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSES TO THE COMMISSION STAFF'S
FIRST PRODUCTION REQUEST NOS. 1-10, 14, 15, 18-21, 23, 24, AND 26-33-8
REQUEST NO. 6: Please provide the cost-effectiveness evaluations for each
DR program for 2004-2012, including all assumptions used.
RESPONSE TO REQUEST NO. 6: Please see the confidential FlexPeak
Management Excel file (Attachment 1), provided on the confidential CD which contains
EnerNOC information that is confidential, proprietary, and/or has commercial value.
The confidential CD will be provided to those parties that have executed the Protective
Agreement in this proceeding. Idaho Power requests references to granular data be
excluded from any Staff reports and/or analysis.
Please also see the Excel files (Attachment 2 and Attachment 3) provided on the
non-confidential CD used to create the program cost-effectiveness pages for Idaho
Power's Demand-Side Management 2011 Annual Report: Supplement I ("Supplement
1"). The Excel files are arranged as follows:
• Summary - A summary of the program life cost-effectiveness based on the
assumptions provided on each tab. This summary sheet appears in Supplement
1.
Inputs - Unique program assumptions which include, but are not limited to,
program life, number of events, participation levels, and incentive.
• B_C Ratios - Combines results from the Program —Benefits and Program—Cost
tabs and calculates annual and program life cost-effectiveness.
Program—Benefits - Combines historical and forecasted performance and
applies alternative costs from the IRP_DSM_Alt._Costs tab.
Program —Costs - Combines historical and forecasted expenses.
• Participants - Combines historical and forecasted participation levels, demand
IDAHO POWER COMPANY'S RESPONSES TO THE COMMISSION STAFF'S
FIRST PRODUCTION REQUEST NOS. 1-10, 14, 15, 18-21, 23, 24, AND 26-33-9
reduction, shifted energy costs, number of events, and number of event hours.
IRP_DSM_Alt._Costs - Financial inputs for cost-effectiveness analysis from the
2011 Integrated Resource Plan ("IRP).
At this time, the cost-effectiveness models have not been updated to include the
2012 expenses and demand reduction results. Additionally, assumptions for future
expenses, participation levels, and anticipated demand reduction have not been
determined. As stated on page 2 of Supplement 1, "...demand response programs are
analyzed over the program life in which historical program demand reduction and
expenses are combined with forecasted program activity to better compare the program
to a supply-side resource." The updated cost-effectiveness results for the demand-
response programs will be available in the Demand-Side Management 2012 Annual
Report: Supplement I on March 15, 2013.
The response to this Request was prepared under the supervision of Theresa
Drake, Customer Relations and Energy Efficiency Manager, Idaho Power Company, in
consultation with Lisa D. Nordstrom, Lead Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSES TO THE COMMISSION STAFF'S
FIRST PRODUCTION REQUEST NOS. 1-10, 14, 15, 18-21, 23, 24, AND 26-33 - 10
REQUEST NO. 7: Please explain how available transmission capacity is
factored into the load and resource balance in the IRP. Does the Company assume all
firm capacity will be utilized in the peak hour?
RESPONSE TO REQUEST NO. 7: The amount of transmission capacity
factored into the IRP load and resource balance is based on a transmission native load
service designation submitted by Idaho Power to its own transmission function in the
autumn season preceding the filing of the IRP. For instance, the amount of
transmission capacity factored into the 2011 IRP load and resource balance is based on
the transmission native load service designation filed in the autumn of 2010. The intent
of this request is to reserve transmission capacity for the Company's retail customers
based on annual load and resource forecasts. Although transmission resources are
owned by Idaho Power, the unreserved transmission capacity may be purchased by
other parties due to the Federal Energy Regulatory Commission's ("FERC") open
access requirements. Idaho Power must reserve the use of its own transmission
system under FERC's open access rules. The Company assumes that all firm capacity
requested for reservation is utilized in the peak hour. A discussion of transmission
resources in the IRP planning period is provided on pages 68-69 of the 2011 IRP.
The response to this Request was prepared by M. Mark Stokes, Director of
Water and Resource Planning, Idaho Power Company, in consultation with Lisa D.
Nordstrom, Lead Counsel, Idaho Power Company
IDAHO POWER COMPANY'S RESPONSES TO THE COMMISSION STAFF'S
FIRST PRODUCTION REQUEST NOS. 1-10, 14, 15, 18-21, 23, 24, AND 26-33 - 11
REQUEST NO. 8: For 2006 through 2012, please provide monthly generation
output for June, July and August for each of the Company's SCCT gas plants.
RESPONSE TO REQUEST NO. 8: The response to this Request is confidential
and will be provided separately to those parties that have signed the Protective
Agreement in this proceeding.
The response to this Request was prepared by Mel Chick, Generation Dispatch
Supervisor, Idaho Power Company, in consultation with Lisa D. Nordstrom, Lead
Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSES TO THE COMMISSION STAFF'S
FIRST PRODUCTION REQUEST NOS. 1-10, 14, 15, 18-21, 23, 24, AND 26-33 -12
REQUEST NO. 9: For 2006 through 2012, please provide the number of hours
by month for June, July and August that each of the Company's SCCT plants ran.
RESPONSE TO REQUEST NO. 9: The response to this Request is confidential
and will be provided separately to those parties that have signed the Protective
Agreement in this proceeding.
The response to this Request was prepared by Mel Chick, Generation Dispatch
Supervisor, Idaho Power Company, in consultation with Lisa D. Nordstrom, Lead
Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSES TO THE COMMISSION STAFF'S
FIRST PRODUCTION REQUEST NOS. 1-10, 14, 15, 18-21, 23, 24, AND 26-33 - 13
IRRIGATION PEAK REWARDS
REQUEST NO. 10: For 2006 through 2012, please provide the following
information for the Irrigation Peak Rewards Program delineated by Option 1, 2, 3 and
Timer:
a.Amount of load under contract
b.Number of service points
C. Number of customers
d.Amount of incentive paid (with workpapers used in the calculations)
e.Incentive payment structure
f.Non-incentive program costs, by category
g.Number and duration of dispatch events
h.Number of opt-outs
RESPONSE TO REQUEST NO. 10: In this request information is requested
delineated by Option 1, 2, 3 and Timer. Please note that Options I and 2 are the same
except under Option I participants can use the load control device for their own
communication and under Option 2 they cannot. There is no difference in the incentive
structure or parameters of the program between Option I and 2. For this reason when
available, the information requested is reported combining Option's I and 2.
a. Amount of load under contract (kW) in both Idaho and Oregon
Year Option I & 2 Option 3 Timer Options Totals
2012 330,066 72,194 13,199 415,459
2011 315,179 75,411 20,184 410,774
2010 259,608 66,736 43,024 369,368
2009 179,946 63,836 58,057 301,839
2008 N/A N/A 164,733 164,733
2007 N/A N/A 182,499 182,499
2006 N/A N/A 179,307 179,307
IDAHO POWER COMPANY'S RESPONSES TO THE COMMISSION STAFF'S
FIRST PRODUCTION REQUEST NOS. 1-10, 14, 15, 18-21, 23, 24, AND 26-33 -14
b. Number of service points in both Idaho and Oregon
Year Option I & 2 Option 3 Timer Options Totals
2012 2,315 35 83 2,433
2011 2,177 37 128 2,342
2010 1,729 30 279 2,038
2009 1,105 25 382 1,512
2008 N/A N/A 897 897
2007 N/A N/A 947 947
2006 N/A N/A 906 906
C. The number of customers is not separated by the options offered in the
Irrigation Peak Rewards program because individual customers participate in multiple
options. Total customers by year are listed below for both Idaho and Oregon.
Year Customers
2012 625
2011 547
2010 508
2009 374
2008 374
2007 257
2006 229
d. Please see Excel file (Attachment 1) provided on the non-confidential CD
which shows Irrigation Peak Rewards total expenses by category from 2006 to 2012.
Not delineated by Option.
Idaho Powers financial system does not permanently store the incentive
information by Option for the Irrigation Peak Rewards program. From 2006 to 2008 only
the Timer Options were available, so all the incentives paid were for the Timer Option.
For the years from 2009 to 2011, the incentive payments by Option are not available.
IDAHO POWER COMPANY'S RESPONSES TO THE COMMISSION STAFF'S
FIRST PRODUCTION REQUEST NOS. 1-10, 14, 15, 18-21, 23, 24, AND 26-33 -15
For 2012 the Company has delineated the incentives by program Option (shown in the
table below); however the total incentives paid will not match the total in Attachment I
because of cross-year billing corrections that were not tracked by program option.
Year
Option
1&2 Option 3 Timer Options Total
2012 $8,677,185 $2,220,180 $128,123 $11,025,488
As discussed with Staff on February 6, the incentives paid to participants in the
Irrigation Peak Rewards program for Options 1, 2, and the Timer Options are calculated
in Idaho Power's billing system and paid through a bill credit. The incentives paid to
participants under Option 3 are calculated in an Idaho Power database system that
collects data from the Company's metering and billing systems. These incentives are
paid through checks issued to the customers.
Idaho Power has provided an example of bill credits under Option I or 2 in
Attachment 2 provided on the non-confidential CD. For an example of an Option 3
participant please see Attachment 3 provided on the non-confidential CD. Customer
specific information has been redacted in both examples
e.The Incentive payment structures are defined in Idaho Power's Tariffs filed
with the Commission. Provided on the non-confidential CD (Attachment 4-Attachment
10) are copies of the Rate Schedule 23 dated: June 1, 2006, November 30, 2006,
March 1, 2008, January 14, 2009, May 15, 2009, January 4, 2010, and March 15, 2011.
f.Please see Idaho Power's response to Staffs Production Request No.
10.d.
g.Please see Idaho Power's response to Staffs Production Request No. 5.a.
h.Please see Idaho Power's response to Staffs Production Request No. 5.c.
IDAHO POWER COMPANY'S RESPONSES TO THE COMMISSION STAFF'S
FIRST PRODUCTION REQUEST NOS. 1-10, 14, 15, 18-21, 23, 24, AND 26-33 -16
The response to this Request was prepared under the supervision of Theresa
Drake, Customer Relations and Energy Efficiency Manager, Idaho Power Company, in
consultation with Lisa D. Nordstrom, Lead Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSES TO THE COMMISSION STAFF'S
FIRST PRODUCTION REQUEST NOS. 1-10, 14, 15, 18-21, 23, 24, AND 26-33 -17
REQUEST NO. 14: Please provide the data used for the Peak-hour Deficits
without Demand Response or B2H on page 7 of Mr. Stokes' testimony. Please provide
the answer in an executable excel file.
RESPONSE TO REQUEST NO. 14: Please see the confidential Excel file
provided on the confidential CD. The confidential CD will be provided to those parties
that have executed the Protective Agreement in this proceeding.
The response to this Request was prepared by M. Mark Stokes, Director of
Water and Resource Planning, Idaho Power Company, in consultation with Lisa D.
Nordstrom, Lead Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSES TO THE COMMISSION STAFF'S
FIRST PRODUCTION REQUEST NOS. 1-10, 14, 15, 18-21, 23, 24, AND 26-33 -18
REQUEST NO. 15: From the Company's perspective, has the use of DR
delayed any transmission or distribution costs due to capacity constraints either to or
within its system? What led the Company to this conclusion?
RESPONSE TO REQUEST NO. 15: Idaho Power is not aware of specific
examples of demand response delaying the need for transmission and distribution
upgrades. However, to the extent that DR could replace a planned generating resource
requiring a transmission upgrade, the DR could then delay the transmission upgrade.
The response to this Request was prepared by Tessia Park, Load Serving
Operation Director, Idaho Power Company, in consultation with Lisa D. Nordstrom,
Lead Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSES TO THE COMMISSION STAFF'S
FIRST PRODUCTION REQUEST NOS. 1-10, 14, 15, 18-21, 23, 24, AND 26-33 -19
REQUEST NO. 18: Ms. Drake claims that the Company "is aware that there may
be additional stakeholders interested in working with the Company to better understand
this process [DR suspension] and will coordinate discussions as necessary" (p. 8).
Beyond the current EEAG members, who has the Company identified that may be
interested? How will the Company solicit and encourage other diverse individuals and
organizations to participate in the process?
RESPONSE TO REQUEST NO. 18: Idaho Power disagrees with Staffs
insertion of [DR suspension] in the quote of Ms Drake's testimony in Staff's Production
Request No. 18. In her testimony Ms. Drake was referring to the proposed process for
stakeholder input into the potential changes for the A/C Cool Credit and Irrigation Peak
Reward programs post 2013, not the suspension of DR programs in 2013.
Idaho Power envisions the collaborative workshops to determine potential
changes and need for all demand response programs post 2013 to be an open process
with anyone interested being able to participate. This might include but not be limited to
members of the Energy Efficiency Advisory Group ("EEAG"), the Integrated Resource
Plan Advisory Council ("IRPAC"), interveners in this case, contractors, regional or
national experts on demand response, and individual customers of Idaho Power. The
Company envisions soliciting and encouraging others to participate in the process
through the EEAG, the IRPAC, and the Commission.
The response to this Request was prepared under the supervision of Theresa
Drake, Customer Relations and Energy Efficiency Manager, Idaho Power Company, in
consultation with Lisa D. Nordstrom, Lead Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSES TO THE COMMISSION STAFF'S
FIRST PRODUCTION REQUEST NOS. 1-10, 14, 15, 18-21, 23, 24, AND 26-33-20
REQUEST NO. 19: Please provide the amount of demand response incentives
included in normalized 2013-2014 PCA power supply expenses. Please separate by
program.
RESPONSE TO REQUEST NO. 19: The Company's current base rates include
a "normalized" level of demand response incentive recovery of $11.3 million from which
deviations will be tracked through the 2013-2014 Power Cost Adjustment ("PCA"). The
Company has not yet forecast the level of demand response incentive payments that
will be included in the 2013-2014 PCA filing that will be made on April 15, 2013. The
program breakout for the normalized recovery in base rates is:
AC Cool Credit: $769,647.48
Flex Peak Management: $1,993,222.50
Irrigation Peak: $8,489,395.50
Total: $11,252,265.48
The response to this Request was prepared by Scott Wright, Regulatory Analyst
II, Idaho Power Company, in consultation with Lisa D. Nordstrom, Lead Counsel, Idaho
Power Company.
IDAHO POWER COMPANY'S RESPONSES TO THE COMMISSION STAFF'S
FIRST PRODUCTION REQUEST NOS. 1-10, 14, 15,18-21,23,24, AND 26-33 -21
REQUEST NO. 20: Please provide the final expense of each demand response
program booked in 2012. Please classify by customer incentive, labor/administration,
materials & equipment, other expense, and purchased services.
RESPONSE TO REQUEST NO. 20: Please see the Excel file provided on the
non-confidential CD.
The response to this Request was prepared under the supervision of Theresa
Drake, Customer Relations and Energy Efficiency Manager, Idaho Power Company, in
consultation with Lisa D. Nordstrom, Lead Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSES TO THE COMMISSION STAFF'S
FIRST PRODUCTION REQUEST NOS. 1-10, 14, 15, 18-21, 23, 24, AND 26-33-22
REQUEST NO. 21: Please provide the current Energy Efficiency Rider balance.
RESPONSE TO REQUEST NO. 21: The response to this Request is
confidential and will be provided separately to those parties that have signed the
Protective Agreement in this proceeding.
The response to this Request was prepared under the supervision of Theresa
Drake, Customer Relations and Energy Efficiency Manager, Idaho Power Company, in
consultation with Lisa D. Nordstrom, Lead Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSES TO THE COMMISSION STAFF'S
FIRST PRODUCTION REQUEST NOS. 1-10, 14, 15, 18-21, 23, 24, AND 26-33-23
REQUEST NO. 23: Specifically, what date did the Company decide to suspend
DR programs?
RESPONSE TO REQUEST NO. 23: On December 14, 2012, members of Idaho
Power's senior executive team were presented with a recommendation to file for the
suspension of the A/C Cool Credit and Irrigation Peak Rewards. The senior executive
team directed the preparation of such a filing and subsequently gave final approval of
that regulatory filing on December 20, 2012.
The response to this Request was prepared under the supervision of Theresa
Drake, Customer Relations and Energy Efficiency Manager, Idaho Power Company, in
consultation with Lisa D. Nordstrom, Lead Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSES TO THE COMMISSION STAFF'S
FIRST PRODUCTION REQUEST NOS. 1-10, 14, 15, 18-21, 23, 24, AND 26-33-24
NC COOL CREDIT
REQUEST NO. 24: Following the July 15, 2013 program vendor expiration date,
and assuming the program will be temporarily suspended, why does the Company claim
that it needs continued access to the vendor's participant database?
RESPONSE TO REQUEST NO. 24: The vendor's participant database holds
valuable participant data, such as active device identifications, historical customer
participation and communications, etc. The Company believes these records must be
kept current so if the program is operational in the future, participants will be accurately
identified for communication, cycling, and incentive payments. It will also help identify
the exact number of active devices in the field in order to predict the potential demand
reduction.
The response to this Request was prepared under the supervision of Theresa
Drake, Customer Relations and Energy Efficiency Manager, Idaho Power Company, in
consultation with Lisa D. Nordstrom, Lead Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSES TO THE COMMISSION STAFF'S
FIRST PRODUCTION REQUEST NOS. 1-10, 14, 15, 18-21, 23, 24, AND 26-33-25
REQUEST NO. 26: In the event that the Company is unable to renegotiate its
contract with the current vendor and a HVAC contractor must be used to remove
devices, how much does the Company estimate it will incur should a qualified HVAC
company remove the load control devices in place of the existing contractor? What are
the costs associated with the Company managing the customer service and database
maintenance?
RESPONSE TO REQUEST NO. 26: In light of the contract that was
renegotiated with its third-party vendor, the Company has not prepared cost estimates
for the hypothetical situation presented. The new contract includes no new installations,
receiving customer service calls during normal business hours, processing of customer
service requests (removals and troubleshooting), processing move in/outs and removal
of equipment when appropriate, maintaining the existing client server database which
interfaces with the Company's CIS system, and storing the remaining inventory of
switches until Idaho Power can relocate them. The cost of these contractor services is
approximately $450,000, but will vary based on the number of service calls and switch
removals.
The response to this Request was prepared under the supervision of Theresa
Drake, Customer Relations and Energy Efficiency Manager, Idaho Power Company, in
consultation with Lisa D. Nordstrom, Lead Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSES TO THE COMMISSION STAFF'S
FIRST PRODUCTION REQUEST NOS. 1-10, 14, 15, 18-21, 23, 24, AND 26-33-26
REQUEST NO. 27: What was the last date in which an A/C Cool Credit load
control device was removed, repaired or installed at a customer location in 2012? How
many devices were removed, repaired or replaced in December 2012?
RESPONSE TO REQUEST NO. 27: The last date that a load control device was
removed was December 31, 2012. The last date that a device was repaired was
August 24, 2012. The last date that a device was installed was December 31, 2012,
when two devices were installed. In December 2012, 143 switches were removed, I
switch was serviced, none were repaired, 1,172 of the paging switches were replaced
with AMI switches and I was replaced because of a faulty switch.
Idaho Power's third-party vendor continued replacing paging switches with AMI
switches until the end of 2012 based on the contract with Idaho Power. According to
the terms of the contract, Idaho Power may terminate the agreement, in whole or in
part, without cause and without penalty by providing them with fifteen (15) days written
notice. On December 14, 2012, Idaho Power provided its third-party contractor with
notice of termination for work dealing with new enrollments and new retrofit installations.
In its termination notice, Idaho Power directed the contractor to immediately discontinue
new enrollments and retrofit installations of A/C Cool Credit switches; however, based
upon a December 14 termination notice, termination did not occur until December 29,
2012.
The response to this Request was prepared under the supervision of Theresa
Drake, Customer Relations and Energy Efficiency Manager, Idaho Power Company, in
consultation with Lisa D. Nordstrom, Lead Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSES TO THE COMMISSION STAFF'S
FIRST PRODUCTION REQUEST NOS. 1-10, 14, 15, 18-21, 23, 24, AND 26-33-27
REQUEST NO. 28: What was the final Company cost of upgrading AMI
compatible NC Cool Credit switches?
RESPONSE TO REQUEST NO. 28: The response to this Request is
confidential and will be provided separately to those parties that have signed the
Protective Agreement in this proceeding.
The response to this Request was prepared under the supervision of Theresa
Drake, Customer Relations and Energy Efficiency Manager, Idaho Power Company, in
consultation with Lisa D. Nordstrom, Lead Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSES TO THE COMMISSION STAFF'S
FIRST PRODUCTION REQUEST NOS. 1-10, 14, 15, 18-21, 23, 24, AND 26-33-28
REQUEST NO. 29: Did the Company alter how it operated the Mountain Home
load control program for the 2012 program year?
RESPONSE TO REQUEST NO. 29: Yes. In 2011 paging services were
discontinued in the Mountain Home region, which prevented the use of Idaho Powers
load control switches on the Mountain Home Air Force Base ("MHAFB"). Because of
the inability to cycle the switches on the MHAFB, the Company did not pay MHAFB any
incentives in 2012.
The response to this Request was prepared under the supervision of Theresa
Drake, Customer Relations and Energy Efficiency Manager, Idaho Power Company, in
consultation with Lisa D. Nordstrom, Lead Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSES TO THE COMMISSION STAFF'S
FIRST PRODUCTION REQUEST NOS. 1-10, 14, 15, 18-21, 23, 24, AND 26-33 -29
REQUEST NO. 30: If the NC Cool Credit program were to be fully eliminated,
what are the costs associated with removing all devices? What other costs would the
Company incur?
RESPONSE TO REQUEST NO. 30: Idaho Power has approximately 38,200
active load control devices installed. Under the current contract with Idaho Power's
third-party vendor, the removal cost for each device is approximately $85 which equals
$3,247,000, assuming the removal is done in one visit; it is possible that some locations
would require more than one visit, adding to this cost. Additionally, Idaho Power would
incur costs associated with notifying participants by direct mail, including printing,
envelopes, and postage, and costs related to door hangers left to notify customer's that
their load control device was removed. The Company would also experience additional
call volume to its customer service center, adding to costs.
The response to this Request was prepared under the supervision of Theresa
Drake, Customer Relations and Energy Efficiency Manager, Idaho Power Company, in
consultation with Lisa D. Nordstrom, Lead Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSES TO THE COMMISSION STAFF'S
FIRST PRODUCTION REQUEST NOS. 1-10, 14, 15, 18-21, 23, 24, AND 26-33-30
REQUEST NO. 31: Please provide the dates and times that the A/C Cool Credit
program was dispatched in 2012 and the average demand reduction per unit.
RESPONSE TO REQUEST NO. 31:
Date % Cycling
Boise
Metro
Temp
Twin
Falls
Pocatello
Temp
Data
source
Max kW
Reduction I unit
June 21, 2012 65% 950 890 AMI 0.5
July 02, 2012 100%(l hr) 950 890 AMI 0.25
July 11, 2012 60% 990 940 AMI 0.33
July 12, 2012 60% 1060 990 AMI 1.09
July 19, 2012 65% 1040 950 AMI 0.95
July 25, 2012 50% 970 950 AMI 0.37
July 31, 2012 70% 970 94° AMI 0.89
August 13, 2012 50% 970 930 AMI 0.4
August 16, 2012 75% 930 920 AMI 0.8
August 20, 2012 65% 940 850 AMI 0.57
August 22, 2012 100%(l hr) 900 870 AMI 0.85
It should be noted, the average load reduction across events for 2012 does not
represent the potential peak load reduction. In 2012, Idaho Power contracted with PECI
to conduct research associated with the load reduction for the A/C Cool Credit program.
Under the plan developed by PECI, Idaho Power experimented with various cycling
strategies at various temperature bins and specifically did not cycle on some days to be
used as control days. The entire study conducted by PECI will be included in Idaho
Power's Demand-Side Management 2012 Annual Report, Supplement 2: Evaluation
filed with the Commission on March 15, 2013. Because the data source for the table
above was AMI hourly load data, the kilowatt ("kW") reduction per unit column is based
on hourly data.
IDAHO POWER COMPANY'S RESPONSES TO THE COMMISSION STAFF'S
FIRST PRODUCTION REQUEST NOS. 1-10, 14, 15, 18-21, 23, 24, AND 26-33-31
The response to this Request was prepared under the supervision of Theresa
Drake, Customer Relations and Energy Efficiency Manager, Idaho Power Company, in
consultation with Lisa D. Nordstrom, Lead Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSES TO THE COMMISSION STAFF'S
FIRST PRODUCTION REQUEST NOS. 1-10, 14, 15, 18-21, 23, 24, AND 26-33-32
FLEXPEAK
REQUEST NO. 32: Ms. Drake states that IPC has begun conversations with
EnerNoc to reduce the costs of the program for 2013. In what areas does the Company
believe it can reduce the costs associated with FlexPeak Management?
RESPONSE TO REQUEST NO. 32: The Company has begun conversation with
EnerNOC pertaining to potential contract modifications. These conversations are on-
going and Idaho Power does not wish to speculate about potential cost reductions at
this time.
The response to this Request was prepared by Lisa D. Nordstrom, Lead
Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSES TO THE COMMISSION STAFF'S
FIRST PRODUCTION REQUEST NOS. 1-10, 14, 15, 18-21, 23, 24, AND 26-33-33
REQUEST NO. 33: What are the costs associated with maintaining the
FlexPeak program for 2013? Please delineate the PCA payments from Rider
payments.
RESPONSE TO REQUEST NO. 33: The response to this Request is
confidential and will be provided separately to those parties that have signed the
Protective Agreement in this proceeding.
The response to this Request was prepared under the supervision of Theresa
Drake, Customer Relations and Energy Efficiency Manager, Idaho Power Company, in
consultation with Lisa D. Nordstrom, Lead Counsel, Idaho Power Company.
DATED at Boise, Idaho, this 21st day of February 2013.
IA A. kftON
Attorney for Idaho Power Company
IDAHO POWER COMPANY'S RESPONSES TO THE COMMISSION STAFF'S
FIRST PRODUCTION REQUEST NOS. 1-10, 14, 15, 18-21, 23, 24, AND 26-33-34
CERTIFICATE OF MAILING
I HEREBY CERTIFY that on the 21st day of February 2013 I served a true and
correct copy of the within and foregoing IDAHO POWER COMPANY'S RESPONSES
TO THE COMMISSION STAFF'S FIRST PRODUCTION REQUEST NOS. 1-10, 14, 15,
18-21, 23, 24, AND 26-33 upon the following named parties by the method indicated
below, and addressed to the following:
Commission Staff
Donald L. Howell, II
Deputy Attorney General
Idaho Public Utilities Commission
472 West Washington (83702)
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
29814 Lake Road
Bay Village, Ohio 44140
Idaho Conservation League
Benjamin J. Otto
Idaho Conservation League
710 North Sixth Street
Boise, Idaho 83702
X Hand Delivered
U.S. Mail
Overnight Mail
FAX
X Email don. howellcpuc.idaho.aov
Hand Delivered
U.S. Mail
Overnight Mail
FAX
X Email elo(äracinelaw.net
Hand Delivered
U.S. Mail
Overnight Mail
FAX
X Email tonyyankeI.net
Hand Delivered
U.S. Mail
Overnight Mail
FAX
X Email bottotidahoconservation.org
IDAHO POWER COMPANY'S RESPONSES TO THE COMMISSION STAFF'S
FIRST PRODUCTION REQUEST NOS. 1-10, 14, 15, 18-21, 23, 24, AND 26-33-35
Snake River Alliance Hand Delivered
Ken Miller, Clean Energy Program Director US. Mail
Snake River Alliance Overnight Mail
P.O. Box 1731 FAX
Boise, Idaho 83701 X Email kmiller(snakeriveralliance.om
Elizabeth Paynte4ëgal Assistant
IDAHO POWER COMPANY'S RESPONSES TO THE COMMISSION STAFF'S
FIRST PRODUCTION REQUEST NOS. 1-10, 14, 15, 18-21, 23, 24, AND 26-33-36