20140206IPC to Staff 1-8.pdf

3Effi*.
An IDACORP Company
DONOVAN E. WALKER
Lead Counsel
dwal ker@idah ooower.com
February 6,2014
VIA HAND DELIVERY
Jean D. Jewell, Secretary
ldaho Public Utilities Commission
472 W est Washington Street
Boise, ldaho 83702
Re: Case No. !PC-E-13-21
ldaho Power Company's SAR Capacity Sufficiency 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 ldaho
Power Company's Response to the First Production Request of the Commission Staff
("Staff') to ldaho Power Company.
DEW:evp
Enclosures
l:i
1221 W. ldaho 5t. (83702)
P.O. Box 70
Boise, lD 83707
onovan E. Walker
DONOVAN E. WALKER (lSB No. 5921)
ldaho Power Company
1221West ldaho Street (83702)
P.O. Box 70
Boise, ldaho 83707
Telephone: [phone]
Facsimile: [phone]
[e-mail]
Attorney for ldaho Power Company
IN THE MATTER OF IDAHO POWER
COMPANY'S APPLICATION FOR
APPROVAL OF ITS CAPACITY
DEFICIENCY PERIOD TO BE UTILIZED IN
THE COMPANY'S SAR METHODOLOGY.
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
CASE NO. IPC-E-13-21
IDAHO POWER COMPANY'S
RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO
POWER COMPANY
COMES NOW, ldaho Power Company ("ldaho Powe/' or "CompEry"), and in
response to the First Production Request of the Commission Staff to ldaho Power
Company dated January 16,2014, herewith submits the following information:
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 1
REQUEST NO. 1: Please provide all documentation supporting ldaho Powe/s
assertion that it will acquire approximately the same amount of demand response in
2014 as in 2012 given that the terms of the 2013 settlement adopted by the
Commission in Order No. 32923 (1) reduce fixed incentive payments to participants, (2)
mandate at least three interruptions each season, (3) limit recruitment of residential and
commercial/industrial customers, and (4) preclude new irrigation participation.
RESPONSE TO REQUEST NO. 1: ldaho Power did not assert that it will acquire
approximately the same amount of demand response in 2014 as in 2012, but the
Company believes that it is a reasonable assumption that it can satisfy the deficit of 30
Megawatts ("MW") in 2014 as shown in the Company's Application on Table 2 with its
existing demand response programs if necessary.
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 - 2
REQUEST NO. 2: Please provide the current number of A/C Cool Credit
participants, the amount of demand reduction expected from each participant, the
expected realization rate, source of the realization rate, and the total amount of demand
response expected to be realized from this program in 2014.
RESPONSE TO REQUEST NO. 2: As of January 27, 2014, the number of A/C
Cool Credit participants was 31,138. The amount of demand reduction per participant
varies with outdoor temperature and percent cycling as shown on page 14 of NC Cool
Credit Program Research Resu/fs, a third-party report produced by PECI, dated
December 2012 and included in ldaho Power's Demand-Side Management 2012
Annual Report, Supplement 2: Evaluation filed with the ldaho Public Utilities
Commission on March 15, 2013. This report can be found at
https://www.idahopower.com/pdfs/AboutUs/RatesRequlatory/Reports/60.pdf. The
Company will use the results of this study as well as Advanced Metering lnfrastructure
('AM!") hourly meter data to estimate load reduction from the A/C Cool Credit program.
ldaho Power has not forecast the total amount of demand reduction expected from the
A/C Cool Credit program in 2014, however the Company believes that it is a reasonable
assumption that it can satisfy the deficit of 30 MW in 2014 as shown in the Company's
Application on Table 2 with all its existing demand response programs if necessary.
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.3
REQUEST NO. 3: PIease provide the annual attrition rate for A/C
participants in 2010,2011,2012, and 2013.
RESPONSE TO REQUEST NO. 3:
Cool Credit
Year
Total
Participants
Total
Attrition
Total %
Attrition
2013*31,427 3,773 12.010/o
2012 36.454 3,807 10.440/0
2011 37,728 4,048 10.7Oo/o
2010 34.640 3,644 10.50%
*2013 participant counts and total attrition counts are preliminary
The attrition rate includes both participants who have moved and participants
who have quit for other reasons.
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 - 4
REQUEST NO. 4: Please provide the current number of FlexPeak participants
(sites) which are under contract for the 2014 season, the total amount of
commercial/industrial demand response under contract for the 2014 season, the
expected realization rate, source of the realization rate, and the total amount of demand
response expected to be realized from this program in 2014.
RESPONSE TO REQUEST NO. 4: Under ldaho Powe/s current agreement with
EnerNOC lnc. ("EnerNOC"), which expires in February 2014, the Company does not
contract directly with customers. EnerNOC contracts directly with FlexPeak participants
and the participant contracts are contingent upon Idaho Power and EnerNOC having an
agreement in place.
Historically, the FlexPeak program has not used a realization rate to determine
load reduction. Because each site has interval metering, it is possible to use recent
historical interval data to determine a baseline which is compared to interval meter data
collected during each event to determine actual load reduction. ldaho Power does not
have a forecast of the total amount of demand reduction from this program tor 2014.
However, the Company believes that it is a reasonable assumption that it can satisfy the
deficit of 30 MW in 2014 as shown in the Company's Application on Table 2 with its
existing demand response programs if necessary.
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.5
REQUEST NO. 5: Does ldaho Power plan to contract with EnerNoc or another
third-party aggregator to provide commercial/industrial demand response in 2014? lf
so, please explain the status of the contract negotiations. lf not, please explain in detail
how ldaho Power plans to acquire the amount of commercial/industrial demand
response expected to be realized in 2014.
RESPONSE TO REQUEST NO. 5: ldaho Power is currently under confidential contract
negotiations with EnerNoc to provide commercial/industria! demand response in 2014.
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: Please provide the current number of lrrigation Peak Rewards
participants (service points) under contract for the 2014 program season, the total
amount of irrigation demand response under contract for the 2014 season, the expected
realization rate, source of the realization rate, and the total amount of demand response
expected to be realized from this program in2014.
RESPONSE TO REQUEST NO. 6: Currently, ldaho Power does not have any
demand response service points under contract in the lrrigation Peak Rewards program
for the 2014 season. ldaho Power is engaged in its annual process of enlisting
participants for the program. This includes the mailing of a letter, new contract
agreement, and worksheet to all irrigation customers that have service locations with
load control devices and to customers with service locations with greater than 1,000
horsepower that have participated in the program in the past. This mailing will kick off
the sign-up season which will continue through March 2014. ln addition to the mailing,
ldaho Power wil! be discussing the program at irrigation workshops and Idaho Power's
Agricultural Representatives will be consulting with former participants to answer
questions and encourage enrollment in the program.
The Company will use realization rates identified in the 2012 lrrigation Peak Reward
Program Report dated December 31, 2012, and included in ldaho Power's Demand-
Side Management 2012 Annual Report, Supplement 2: Evaluation ftled with the ldaho
Public Utilities Commission on March 15, 2013. This report can be found at
https://www.idahopower.com/pdfs/AboutUs/RatesRequlatorv/Reports/60.pdf.
Additionally ldaho Power anticipates hiring a third-party contractor in 2014 to conduct an
analysis of AMI and interva! meter data.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 7
ldaho Power has not forecast the total amount of demand reduction expected
from the lrrigation Peak Rewards program tn2014; however, the Company believes that
it is a reasonable assumption that it can satisfy the deficit of 30 MW in 2014 as shown in
the Company's Application on Table 2 with its existing demand response programs if
necessary.
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 - 8
REQUEST NO. 7: lf the amount of irrigation demand response currently under
contract is different from the amount ldaho Power expects to have for the 2014 season,
please explain how ldaho Power plans to acquire the amount of irrigation demand
response expected to be realized in 2014.
RESPONSE TO REQUEST NO. 7: Please see the Company's response to
Staffs Production Request No. 6.
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 - 9
REQUEST NO. 8: Does ldaho Power believe that the terms of the Commission
approved 2013 settlement (Order No. 32923), which reduces incentive payment
amounts and increases interruption, will over time reduce the participation rates and
reliability of its irrigation demand response program? Please explain why or why not.
RESPONSE TO REQUEST NO. 8: Yes, the Company expects reduced
participation as a result of the 2013 settlement agreement; however, the Company is
required to offer all existing participants the opportunity to participate which could add
up to 440 MW of peak reduction from all of the Company's demand response programs.
The Company does not know the magnitude of the possible reduction, yet it is
reasonable to expect that the Company can satisfy the potential deficit of 30 MW in
2014 as shown in the Company's Application on Table 2 with its existing demand
response programs. ldaho Power believes that the terms of the Commission approved
2013 settlement (Order No. 32923) will not decrease the reliability of the lrrigation Peak
Reward demand reduction because the settlement specifies that the Company will use
the program at least three times during the season under the fixed incentive, which will
have the effect of continually managing the expectations of both the participants and the
Company on what to expect during events. Additionally, the Settlement (page 3 of
Order No. 32923) states:
The Company will implement DR programs using the following
concepts:
4. Re-evaluate the value calculation as the IRP changes;
And page 7 states:
We also encourage the Company to continue evaluating
opportunities associated with DR programs on an ongoing
basis. Circumstances such as increased demand related to
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 1O
business relocation and expansion, coupled with increased
residential construction can occur quickly and impact the
system well before a future IRP formally indentifies the
increased demand. Accordingly, ongoing review could lead
to adjustments to DR programs that might reduce the risk of
buying wholesale power at costs that exceed the recovery of
DR expenses.
These provisions will allow a re-evaluation of demand response and adjustment of
program provisions and design when necessary.
The response to this Request is sponsored by Pete Pengilly, Customer Research
and Analysis Leader, ldaho Power Company.
DATED at Boise, ldaho, this 6th day of February 2014.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 11
Attorney for ldaho Power Company
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 6h day of February 2014 t served a true and
conect 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
Kristine A. Sasser
Deputy Attomey General
ldaho Public Utilities Commission
472 West Washington (83702)
P.O. Box 83720
Boise, ldaho 83720-007 4
J.R. Simplot Company
Peter J. Richardson
Gregory M. Adams
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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qreo@richard sonad ams.com
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IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 12