20131028IPC to Staff 1-6.pdf

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An IDACORP Company
VIA HAND DELIVERY
Jean D. Jewell, Secretary
ldaho Public Utilities Commission
472 West Washington Street
Boise, ldaho 83702
Re: Case No. IPC-E-13-15
ldaho Power Company's 2013 lntegrated Resource Plan - ldaho Power
Company's Response to the First Production Request of the Commission
Staff
Dear Ms. Jewell:
Enclosed for filing in the above matter are an original and three (3) copies of Idaho
Power Company's Response to the First Production Request of the Commission Staff
("Staff') to ldaho Power Company.
Also, enclosed are four (4) copies of a confidential disk containing information
responsive to Staffs Production Request No. 1 . Please handle the confidential infonnation
in accordance with the Protective Agreement executed in this matter.
LISA D. NORDSTROM
Lead Gounsel
![e-mail]
October 28,2013
LDN:evp
Enclosures
Sincerely,
X*CV^*+,*,--, \-,
Lisa D. Nordstrom
1221 W. ldaho St. (83702)
P.O. Box 70
8oise, lD 83707
LISA D. NORDSTROM (lSB No. 5733)
JENNIFER M. REINHARDT-TESSMER (lSB No. 7432)
ldaho Power Company
1221Wesl ldaho Street (83702)
P.O. Box 70
Boise, Idaho 83707
Telephone: [phone]
Facsimile: [phone]
I nord strom@idahopower. co m
irei n hardt@ id ahopower. co m
Attorneys for ldaho Power Company
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BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF IDAHO POWER
COMPANY'S 201 3 INTEGRATED
RESOURCE PLAN
CASE NO. IPC-E-13-15
IDAHO POWER COMPANY'S
RESPONSE TO THE FIRST
PRODUCTION REQUEST OF
THE COMMISSION STAFF TO
IDAHO POWER COMPANY
COMES NOW, ldaho Power Company ("ldaho Powed' or "Comp?oy"), and in
response to the First Production Request of the Commission Staff ("Staff') to ldaho
Power Company dated October 7,2013, herewith submits the following information:
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REOUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 1
REQUEST NO. 1: Please provide any analyses conducted by the Company to
quantify how mandatory time-of-use rates for Schedule 19 customers impact class
demand and energy use. lf the Company has not conducted any analysis, please
explain why.
RESPONSE TO REQUEST NO. 1: The confidential Excel file (Attachment 2)
contains the results of ldaho Power Company's ("ldaho Powe/') analysis regarding the
impact of Time of Use rates ("TOU') on Schedule 19 customers. The attached non-
confidential PDF (Attachment 1) is the corresponding memo which summarizes the
results of the study.
The response to this Request is sponsored by M. Mark Stokes, Water and
Resource Planning Director, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 2
REQUEST NO. 2: Please explain how a mandatory time-of-use rate for
Schedule 19 customers has changed the methodology of forecasting peak load for the
industrial class within the lntegrated Resource Plan (!RP).
RESPONSE TO REQUEST NO. 2: The methodology used for forecasting peak
load has not changed due to TOU pricing for Schedule 19 customers.
ldal'io Power's peak forecasting model is designed to model probabilistic monthly
total system peaks for the 2O-year lRP planning horizon, with the 95 percentile (5
percent chance of occurrence) as the planning benchmark. The aggregated average
load derived from energy forecasts and the 95 percentile probability of average peak
day temperatures serve as input to the peak mode!. The energy-based models capture
the impact of pricing such as TOU, the output from the energy based model becomes
the input to the peak model to establish the statistical "outlie/' value of the 95 percentile
system load. The model output is further adjusted for peak reduction strategies such as
demand response programs.
The response to this Request is sponsored by M. Mark Stokes, Water and
Resource Planning Director, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 3
REQUEST NO. 3: What contingency analysis has the Company performed to
enable it to meet its load obligations if Boardman to Hemingway is delayed?
RESPONSE TO REQUEST NO. 3: As noted on page 89 of ldaho Poweds 2013
IRP:
Alternative to Boardman to Hemingway resource portfolios-
Three resource portfolios explore alternatives to the
Boardman to Hemingway transmission line to meet future
resource needs. The Boardman to Hemingway transmission
line is not included in the three resource portfolios. The
three resource portfolios contain the existing and committed
ldaho Power generation resources.
The three Boardman to Hemingway alternative resource portfolios utilize a
combination of demand response programs and new natural gas combined-cycle
combustion turbines to meet ldaho Power's load obligations if the Boardman to
Hemingway transmission line is delayed or not constructed. The three alternative
resource portfolios are identified as resource portfolios 3, 4, and 5 and the portfolios are
described in ChapterS of ldaho Power's 2013 IRP. The results of the analyses of the
three Boardman to Hemingway alternative resource portfolios are presented in Chapter
9 of ldaho Power's 2013lRP.
The response to this Request is sponsored by M. Mark Stokes, Water and
Resource Planning Director, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 4
REQUEST NO. 4: Does the Company's portfolio analysis include any sections
of the Gateway West project? Why or why not?
RESPONSE TO REQUEST NO. 4: As a minority partner, ldaho Power did not
assume energy or capacity benefits from the Gateway West Transmission Project in the
Company's 2013 lRP.
ldaho Power recognizes that the Gateway West Transmission project design
configuration and construction schedule will likely become better defined in future
PacifiCorp resource plans and once federal and state permits are obtained. ldaho
Power intends to address the Gateway West Transmission project in future integrated
resource plans as the design configuration and construction schedule become more
defined.
Additional transmission capacity on Gateway West would increase ldaho Powe/s
ability to both buy and sell electricity on the east side of the system. In addition to
increased market access, Gateway West capacity also provides resource siting options
in southern ldaho that are not currently available due to transmission constraints.
The response to this Request is sponsored by M. Mark Stokes, Water and
Resource Planning Director, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY.5
REQUEST NO. 5: The Company forecasts energy savings of 69 aMW tor 2013-
2017 due to its current demand-side management (DSM) portfolio (!RP, p. 43), and 38
aMW from new energy efficiency savings by 2017 @. a0. Specifically, how does the
Company plan to obtain these savings? What new measures, programs and marketing
efforts will the Company implement to achieve these savings?
RESPONSE TO REQUEST NO. 5: The referenced energy savings of 69 aMW
for 2013-2017 (lRP, p. 43), and 38 aMW by 2017 (p. 44) represents the Company's
forecast of achievable energy savings from existing Demand-Side Management
programs and new energy efficiency opportunities indentified in the Company's 2012
energy efficiency potential study, respectively.
Page 38 of Idaho Power's IRP states: "A complete review of the energy
efficiency potential study and report can be found in the 2012 annual report filing
supplement, Demand-Side Management 2012 Annual Report, Supplement 2:
Evaluation, which is available on the ldaho Power Website at:
http://www. idahopower.com/EnerqvEfficiency/reports.cfm".
The study is located within this report by going to evaluation/other
evaluations/ldaho Power Energy Efficiency Potential Study.
Consistent with its past practice, the Company intends to develop future program
designs and related marketing efforts to achieve the energy savings identified in the IRP
with input and support from the Energy Efficiency Advisory Group.
The response to this Request is sponsored by Pete Pengilly, Customer Research
and Analysis Leader, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 6
REQUEST NO. 6: The 10-year Action Plan does not discuss energy efficiency
as a resource. Please explain why.
RESPONSE TO REQUEST NO. 6: All cost effective and achievable energy
efficiency is included at the load and resource balance stage of the IRP planning
process instead of being included in the Action Plan. lncluding energy efficiency in the
load and resource balance gives energy efficiency the first priority over all other
resource options.
The forecasted contribution of energy efficiency programs are shown on page 44
of the ldaho Power 2013 !RP:
In 2017, the incremental energy efficiency savings will
reduce energy loads by 38 aMW; in 2022, average loads will
be reduced by 76 aMW. The full 2O-year capacity of the
program additions and changes is 188 aMW of average
energy reduction.
Monthly energy and capacity contributions of the new energy efficiency programs
by customer class are shown on pages 31 through 72 of ldaho Power's 20't3 IRP,
Appendix C, Technica! Appendix.
The response to this Request is sponsored by M. Mark Stokes, Water and
Resource Planning Director, ldaho Power Company.
DATED at Boise, Idaho, this 28th day of October 2013.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 7
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this 28th day of October 20131 served a true and
correct copy of IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER
COMPANY upon the following named parties by the method indicated below, and
addressed to the following:
Commission Staff
Karl Klein
Deputy Attorney General
!daho Public Utilities Commission
47 2 W est Washington (83702)
P.O. Box 83720
Boise, ldaho 83720-007 4
ldaho Conservation League
Benjamin J. Otto
ldaho Conservation League
710 North Sixth Street
Boise, ldaho 83702
Snake River Alliance
Ken Miller, Clean Energy Program Director
Snake River Alliance
P.O. Box 1731
Boise, ldaho 83701
J.R. Simplot Company
Peter J. Richardson
RICHARDSON ADAMS, PLLC
515 North 27th Street (83702)
P.O. Box 7218
Boise, ldaho 83707
Dr. Don Reading
6070 Hill Road
Boise, ldaho 83703
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IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY. S
Renewable Energy Coalition
Thomas H. Nelson
P.O. Box 1211
Welches, Oregon 97067
John Lowe, Director
Renewable Energy Coalition
12050 SW Tremont Street
Portland, Oregon 97225
Nancy Esteb, Ph.D.
P.O. Box 490
Carlsborg, Washington 98324
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IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 9
Assistant
BEFORE THE
IDAHO PUBLIG UTILITIES COMMISSION
GASE NO. IPC-E-I3-1 5
IDAHO POWER COMPANY
RESPONSE TO STAFF'S
REQUEST FOR PRODUGTION NO. 1
SEffi*.
DATE:May 2'1,2007
MEMO TO: Maggie Brilz
FROM: Courtney Waites
CC:
SUBJECT: Time-of-Use analysis for ldaho Power's Schedule 19 customers
ln Order No. 29505 dated May 25,2004, the ldaho Public Utilities Commission (IPUC) approved
ldaho Power's request to implement mandatory time-of-use rates (TOU) for Schedule 19 customers. The
rates include on-peak, mid-peak, and off-peak energy prices to be in effect during June, July and August.
During the other nine months, mid-peak and off-peak energy rates are in effect. The intent of this rate
design is to more closely align prices with costs and thus provide the economic signal that energy is more
costly during both the peak hours of the day and the peak months of the year. ln May, 2007, an analysis
was completed to evaluate any impact of the implementation of TOU pricing for ldaho Power's Schedule
19 customers. Described below is a summary of the analysis.
Timeof-Use Analvsis
The purpose of the analysis was to evaluate what impact, if any, TOU rates may have had on
customers' usage patterns during our high demand periods of June, July and August. Hourly data was
retrieved for all Schedule 19 customers during these months in the years 2004, 2005, and 2006. This
data was then grouped by on-peak, mid-peak, and off-peak hours separately for each year and for each
customer. Once the data was grouped, the customers were then sorted into seven customer categories:
manufacturing, food processing, education, city/county/state, medical, office building, and other. The
categories were created to lump customers with similar end-use energy usage together for comparison.
The data for these seven customer classes within Schedule 19 was then graphed, comparing the percent
of energy consumed during each of the TOU periods in 2004, 2005, and 2006. Separately, all the
Schedule 19 customers were sorted by total energy consumed and a line graph was prepared for each of
the top five customers, comparing their energy use for each of the three years.
Findinqs
When looking at the data groups described above, the following two conclusions can be made: 1)
almost all customers use the majority of their energy during the mid-peak hours, the least during the on-
peak-hours, and the off peak hour usage falls in between, and 2) customer usage patterns do not appear
to be influenced by TOU rates. The only customer category that varies slightly from the trend is the office
building categorf those customers consume the most energy during the mid-peak hours like the rest, but
the least energy is consumed during the off-peak hours.
The TOU rates were phased-in in 2004 at the direction of the Commission. Between June I and
Decem ber 1 , 2044 Schedule 19 customers were given two bills: the actual bill to be paid and a second
bill showing the charges had the TOU rates been in effect. Actual bills began reflecting the TOU rates
effective December 1,2004. The goal was to give customers time to prepare to operate cost-effectively
under the new rates. However, over the course of the three years, Schedule 19 customers showed no
noticeable shifting of energy use between the on-peak, mid-peak, and off-peak hours.
Recommendations
!n its Order, the Commission recommended establishing the summer peak energy differentials
conservatively because this was the first time the Company had implemented mandatory TOU rates. lt is
possible that because the differentials are on the conservative side, no incentive for load shifting is
provided. However, it is important to note some rate activities during the course of the TOU rates. During
this time, we came off of six consecutive bad water years for one good water year resulting in a PCA
credit for customers rather than a charge and we had a small base rate increase. ln light of the various
rate activities during this time, it is difficult to determine any definitive conclusions from the usage
patterns. lt is my recommendation we continue to analyze TOU pricing as we are implementing
additional rate activities which may incent customers to shift energy usage. The Company will continue to
send price signals as a more appropriate cost recovery mechanlsm.