20140421IPC to ICIP 1-10.pdf

3Effi*.
An IDACORP Company
1., {1: I I
JULIAA. HILTON
Gorporate Counsel
ih [e-mail]
April 18,2014
VIA HAND DELIVERY
Jean D. Jewell, Secretary
ldaho Public Utilities Commission
472 West Washington Street
Boise, ldaho 83702
Re: Case No. IPC-E-14-02
Third Amendment to Demand Response Agreement with EnerNOC, lnc. -
ldaho Power Company's Response to the First Production Request of the
Industrial Customers of ldaho Power
Dear Ms. Jewell:
Enclosed for filing in the above matter are an original and three (3) copies of ldaho
Power Company's Redacted Response to the First Production Request of the lndustrial
Customers of ldaho Power.
Also, enclosed in separate envelopes are an original and three (3) copies each of
ldaho Power Company's Confidential Response to the First Production Request of the
lndustria! Customers of ldaho Power and the confidential attachment provided in
response to Request for Production No. 2. Please handle the confidentia! information in
accordance with the Protective Agreement executed in this matter.
JAH:csb
Enclosures
1221 W. ldaho st. (83702)
P.O. Box 70
Boise, lD 83707
JULIA A. HILTON (lSB No. 7740)
LISA D. NORDSTROM (lSB No. 5733)
Idaho Power Company
1221West ldaho Street (83702)
P.O. Box 70
Boise, ldaho 83707
Telephone: [phone]
Facsimile: [phone]
ih i lton @ ida hopower. com
I nord strom @ ida hopower. co m
Attorneys for ldaho Power Company
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
rN THE MATTER OF IDAHO POWER )
coMPANy'S PETIT|ON FOR APPROVAL ) CASE NO. IPC-E-14-02
oF TH|RD AMENDMENT TO rTS )
AGREEMENT WITH ENERNOC, lNC. - ) IDAHO POWER COMPANY',S
DEMAND RESPONSE PROGRAM ) REDACTED RESPONSE TO
) THE FrRST PRODUCTTON
) REOUEST OF THE INDUSTRIAL
) cusToMERS OF IDAHO POWER
)
COMES NOW, ldaho Power Company ("ldaho Powe/' or "Company"), and in
response to the First Production Request of the lndustria! Customers of ldaho Power
dated April 7, 2014, herewith submits the following information:
IDAHO POWER COMPANY'S REDACTED RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER - 1
REQUEST FOR PRODUCTION NO. 1: Please provide copies of ldaho Power's
responses to discovery requests by all other parties to this docket.
RESPONSE TO REQUEST FOR PRODUCTION NO. 1: !n the regular course of
business, ldaho Power wi!! provide copies of its responses to discovery requests to the
Industrial Customers of ldaho Power (.ICIP') in this proceeding. To date, ldaho Power
has only responded to the ldaho Public Utilities Commission Staff's ("Staff') First
Production Request. A copy of ldaho Powe/s response to Staffs Request was
previously provided to lClP.
The response to this Request is sponsored by Christa Bearry, Legal
Administrative Assistant, ldaho Power Company.
IDAHO POWER COMPANY'S REDACTED RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER - 2
REQUEST FOR PRODUCTION NO. 2: Page five of the Petition states,
Because these limitations in dispatch were not anticipated by
the parties to the Settlement Agreement, ldaho Power
consulted its Energy Efficiency Advisory Group ("EEAG") on
February 6, 2014, tor feedback. The EEAG supported the
Company moving forward with this additional term in the
Third Amendment.
Please provide the minutes of the February 6,2014 EEAG meeting referenced.
RESPONSE TO REQUEST FOR PRODUCTION NO. 2: Please see the
confidential attachment. The confidential attachment will be provided to those parties
that have signed the Protective Agreement in this proceeding.
The response to this Request is sponsored by Pete Pengilly, Customer Research
and Analysis Leader, ldaho Power Company.
IDAHO POWER COMPANY'S REDACTED RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER - 3
REQUEST FOR PRODUCTION NO. 3: Page five of the Petition states, "The
Third Amendment to the Agreement aligns with the Settlement Agreement approved in
Case No. IPC-E-13-14." Please explain, given that the "limitations in dispatch were not
anticipated," how the program still aligns with the Settlement Agreement.
RESPONSE TO REQUEST FOR PRODUCTION NO. 3: ldaho Power believes
that the third amendment to the EnerNOC, lnc. ("EnerNOC") agreement aligns with the
Settlement Agreement approved in Case No. IPC-E-13-14 because the EnerNOC
agreement uses existing demand response resources when possible (Settlement
Agreement 4.a.i); helps provide offerings for all three customer classes (Settlement
Agreement 4.a.ii); keeps costs as low as possible (Settlement Agreement 4.a.iii);
strives for consistency in dispatch requirements across demand response programs
(Settlement Agreement 4.a.vii); does not seek to expand the capacity of the FlexPeak
Management program (Settlement Agreement 9.a); and the FlexPeak Management
program will be available from June 15 through August 15, Monday through Friday, from
2:00 p.m. to 8:00 p.m., excluding holidays. Each dispatch event will last up to four
hours per participant within the available program hours. Dispatch events wil! not occur
more than 60 hours per season. ln the event of a system emergency, the FlexPeak
Management program wil! be available. ldaho Power will conduct a minimum of three
dispatch events per season. There will be two hours advanced notice to participants
(Settlement Agreement g.b).
The response to this Request is sponsored by Pete Pengilly, Customer Research
and Analysis Leader, ldaho Power Company.
IDAHO POWER COMPANY'S REDACTED RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER - 4
REQUEST FOR PRODUCTION NO. 4: Page five of the Application indicates
the agreement between ldaho Power and EnerNoc "extends the contract termination
date through the of the 2014 program season". Does the Company anticipate
continuing the FlexPeak program beyond the end ol2014? lf so:
A. Does the Company expect to execute a new contract with EnerNoc for the
FlexPeak program? lf so, at what level of participation, megawatts committed, dispatch
hours, and event days does the Company anticipate be included in the new contract?
Please explain fully.
B. ls the Company considering administrating the program in house? lf so,
at what level of participation, megawatts committed, dispatch hours, and event days
does the Company anticipate be included in the program? Please explain fully.
C. ls the Company considering a different contractor to administer the
program? lf so, at what level of participation, megawatts committed, dispatch hours,
and event days does the Company anticipate be included in the new contract with a
different vendoP Please explain fully.
RESPONSE TO REQUEST FOR PRODUCTION NO. 4:
A. Idaho Power plans to offer demand response programs to all three
customer classes (residential, commercial/industrial, and irrigation) in a manner that
aligns with the Settlement Agreement approved in Case No. IPC-E-13-14, Settlement
Agreement 4.a.ii. The Company is currently exploring its options in continuing to offer a
demand response program to the commercial/industrial class beyond 2014.
B. Please see the Company's response to lClP's Request for Production No.
4.A above.
IDAHO POWER COMPANY'S REDACTED RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER - 5
C. Please see the Company's response to lClP's Request for Production No.
4.A above.
The response to this Request is sponsored by Pete Pengilly, Customer Research
and Analysis Leader, ldaho Power Company.
IDAHO POWER COMPANY'S REDACTED RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER - 6
REQUEST FOR PRODUCTION NO. 5: Confidential Attachment 2 'Explanation
of Third Amendment' states,
RESPONSE TO REQUEST FOR PRODUCTION NO. 5:
The response to this Request is sponsored by Pete Pengilly, Customer Research
and Analysis Leader, ldaho Power Company.
IDAHO POWER COMPANY'S REDACTED RESPONSE TO THE FIRST
PRODUCTION REOUEST OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER - 7
REQUEST FOR PRODUCTION NO. 6: What would be the MW dispatched for
each of Idaho Powe/s DR programs (A/C Cool Credits, lrrigation Peak Rewards,
FlexPeak) assuming each of the programs are dispatched only at the minimum levels
required under the IPC-E-13-14 Settlement Agreement? What is the expected cost to
ldaho Power for each program at this minimum level of dispatch?
RESPONSE TO REQUEST FOR PRODUCTION NO. 6: The current enrollment
in demand response programs as of April 7, 2014, is shown in the confidential table
below, which represents the expected capacity and cost for the demand response
programs if dispatched three times (the assumed minimum).
These levels of load reduction reflect the capacity available on days with high
daytime temperatures during the Company's typical annual peak time period in late
June or early July.
The response to this Request is sponsored by Pete Pengilly, Customer Research
and Analysis Leader, ldaho Power Company.
IDAHO POWER COMPANY'S REDACTED RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER - 8
REQUEST FOR PRODUCTION NO. 7: What would be the MW dispatched for
each of ldaho Powe/s DR programs (A/C Cool Credits, lrrigation Peak Rewards,
FlexPeak) assuming each of the programs is dispatched at the full 60 hour limit? What
is the expected cost to ldaho Power for each program at this maximum level of
dispatch?
RESPONSE TO REQUEST FOR PRODUCTION NO. 7: The current enrollment
in demand response programs as of April 7, 2014, is shown in the confidential table
below, which represents the expected capacity and cost for the demand response
programs for each program if used the maximum of 60 hours.
These levels of load reduction reflect the capacity available on days with high
daytime temperatures during the Company's typical annual peak time period in late
June or early July.
The response to this Request is sponsored by Pete Pengilly, Customer Research
and Analysis Leader, Idaho Power Company.
IDAHO POWER COMPANY'S REDACTED RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER - 9
REQUEST FOR PRODUCTION NO. 8: ldaho Power Reply Comments in ldaho
Public Commission case IPC-E-13-21, Attachment 1, for expected peak-hour loads
indicates that Demand Response programs, under 90% hydro exceedence, would
supply 30, 95, 215, 275 MW for the years 2014, 2015, 2016, and 2017 respectively.
Please indicate the Company's expected MW contribution for each of those four years,
for each of the three programs (A/C Cool Credits, lrrigation Peak Rewards, FlexPeak).
Also please indicate the expected cost to the Company for each of fours [src/ for each of
the three programs at the 30, 95, 215,275 MW level of dispatch.
RESPONSE TO REQUEST FOR PRODUCTION NO. 8: The current enrollment
in demand response programs as of April 7, 2014, is shown in the confidentia! table
below, which represents the expected capacity and cost for the demand response
programs for 2014 if dispatched three times (the assumed minimum).
These levels of load reduction reflect the capacity available on a day when high
daytime temperatures during the Company's typical annual peak time period in late
June or early July and exceed the expected capacity deficits through 2017 as identified
in ldaho Power's Reply Comments, Attachment 1 in Case No. IPC-E-13-21. These
IDAHO POWER COMPANY'S REDACTED RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER. 1O
levels of load reduction capacity are achieved with reduced costs, offering the program
only to past participants, and installing little new equipment.
Because demand response programs are capacity programs, the costs are
primarily capacity related.
The confidential table above shows the cost per program with the required three
dispatch events, with approximately 12 hours included in the fixed costs for each
program. The confidential table below shows the costs for each program assuming the
maximum number of dispatch events, 60 hours for each program.
The response to this Request is sponsored by Pete Pengilly, Customer Research
and Analysis Leader, ldaho Power Company.
IDAHO POWER COMPANY'S REDACTED RESPONSE TO THE FIRST
PRODUCTION REOUEST OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER - 11
REQUEST FOR PRODUCTION NO. 9: Does the Company anticipate filing with
third amendment of the EnerNOC contract for FlexPeak program with the Oregon
Commission? lf so when? Please explain why or why not.
RESPONSE TO REQUEST FOR PRODUCTION NO. 9: ldaho Power plans to
make an informational filing of the third amendment to the EnerNOC agreement for the
FlexPeak Management program with the Public Utility Commission of Oregon upon
approva! of the amendment by the ldaho Public Utilities Commission.
The response to this Request is sponsored by Tami White, Manager Rate
Design, Idaho Power Company.
IDAHO POWER COMPANY'S REDACTED RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER - 12
REQUEST FOR PRODUCTION NO. 10: Assuming Contract Amendment No. 3
is approved by the Commission what is the expected impact on the number of
participants currently enrolled in the FlexPeak Program? Please explain fully if the
company expects more or fewer MWs to be available.
RESPONSE TO REQUEST FOR PRODUCTION NO. 10: The third amendment
affects the agreement between ldaho Power and EnerNOC only, not the agreements
between the participants and EnerNOC. The Company expects the available meter-
level demand response capacity in 2014 to average between 30-35 MW. ln 2013, the
average committed meter-leve! demand response capacity was 34 MW.
The response to this Request is sponsored by Pete Pengilly, Customer Research
and Analysis Leader, ldaho Power Company.
DATED at Boise, ldaho, this 18th day of April 2014.
IDAHO POWER COMPANY'S REDACTED RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER. 13
JUIIA A. HILTON
Attorney for ldaho Power Company
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this 18th day of April 2014 I served a true and
correct copy of IDAHO POWER COMPANY'S REDACTED RESPONSE TO THE
FIRST PRODUCTION REQUEST OF THE INDUSTRIAL CUSTOMERS OF IDAHO
POWER upon the following named parties by the method indicated below, and
addressed to the following:
Gommission Staff
Weldon B. Stutzman
Deputy Attorney General
ldaho Public Utilities Commission
472 W est Washington (83702)
P.O. Box 83720
Boise, ldaho 83720-007 4
lndustrial Customers of Idaho Power
Peter J. Richardson
RICHARDSON ADAMS, PLLC
515 North 27th Street
Boise, ldaho 83702
Dr. Don Reading
6070 Hill Road
Boise, ldaho 83703
ldaho Conservation League
Benjamin J. Otto
ldaho Conservation League
710 North Sixth Street
Boise, ldaho 83702
Hand Delivered
U.S. Mail
Overnight Mail
FAXX Email [e-mail]
Hand DeliveredX U.S. Mail
_Overnight Mail
FAXX Email pete r@ richa rd so n ad a ms. co m
Hand Delivered
U.S. Mai!
Overnight Mail
FAX
Email [e-mail]
Hand Delivered
U.S. Mail
Overnight Mail
FAXX Email [e-mail]
IDAHO POWER COMPANY'S REDACTED RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER - 14
Christa Bearry, Lega! Assistant
BEFORE THE
IDAHO PUBLIC UTILITIES GOMMISSION
GASE NO. IPC-E-14-02
IDAHO POWER COMPANY
RESPONSE TO ICIP'S
REQUEST FOR PRODUCTION NO.2
THIS ATTACHMENT IS
CONFIDENTIAL
AND WI LL BE PROVI DED
TO THOSE PARTIES THAT
HAVE SIGNED THE
PROTECTIVE
AGREEMENT