20221102IPC to Staff 1-5.pdf

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Megan Goicoechea Allen
Corporate Counsel
[e-mail]
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Attachments
November 2,2022
VIA ELECTRONIC FILING
Jan Noriyuki, Secretary
ldaho Public Utilities Commission
11331 W. Chinden Blvd., Bldg 8,
Suite 201-A (83714)
PO Box 83720
Boise, ldaho 83720-0074
Re: Case No. IPC-E-22-24
ln the Matter of the Application for a Modification to Add an Automatic
Dispatch Option to the Company's Commercial & lndustrial Demand
Response Program, Schedule 82
Dear Ms. Noriyuki
Attached for electronic filing, please find ldaho Power Company's Response to the
First Production Request of the Commission Staff in the above matter.
If you have any questions about the attached documents, please do not hesitate to
contact me.
Very truly yours,
Tictd^r^0ilorr
Megan Goicoechea Allen
MEGAN GOICOECHEA ALLEN (lSB No. 7623)
LISA D. NORDSTROM (lSB No. 5733)
ldaho Power Company
1221 West ldaho Street (83702)
P.O. Box 70
Boise, ldaho 83707
Telephone: [phone]&t
Facsimile: [phone]
mooicoecheaa [e-mail]
lnordstrom@ida hopower. com
Attorneys for ldaho Power Company
BEFORE THE IDAHO PUBLIC UT!L!T!ES COMMISSION
IN THE MATTER OF IDAHO POWER
COMPANY'S APPLICATION FOR A
MODIFICATION TO ADD AN
AUTOMATIC DISPATCH OPTION TO
THE COMPANY'S COMMERCIAL &
INDUSTRIAL DEMAND RESPONSE
PROGRAM, SCHEDULES2
CASE NO. IPC-E-22-24
IDAHO POWER COMPANY'S
RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO
POWER COMPANY
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COMES NOW, ldaho Power Company ("ldaho Power' or "Company"), and in
response to First Production Request of the Commission Staff f IPUC or Commission")
dated October 14,2022, herewith submits the following information:
IDAHO PO\A'ER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF- 1
REQUEST FOR PRODUCTION NO. 1: Please provide workpapers detailing the
expected cost-effectiveness of the Automated Dispatch Option on the Company's
Commercia! and lndustria! Flex Peak Program. Please provide all workpapers in Exce!
format with all fonnulas enabled. Please include all assumptions on expenses, device
reliability, realization rates, participation, and the bases for these assumptions.
RESPONSE TO REQUEST FOR PRODUCTION NO. 1: ldaho Power reviewed
the cost-effectiveness of adding an automatic option to the Flex Peak program by utilizing
the cost-effectiveness threshold of $52.42 per kilowatt ("k\M) year identified in the
demand response ('DR') modifications case IPC-E-21-32 (Nesbitt Direct Page 33). Using
this threshold, the estimated capacity of the Program (30 MW, and the estimated cost of
the program ($44.17 per kW year), the Company determined there is approximately a
$218,000 (($51.42 - $44.17) x 30,000) gap between what the Company currently
estimates to spend on Flex Peak and the estimated limit for cost effectiveness at current
participant levels. The Company estimates it may get 10-20 participants in the automatic
dispatch option with costs estimated to be between $1,160 - $1,500 per site including
device and installation. When incorporating these costs and the benefits from additional
participants, there is still an approximate $189,000 (($51.42 - $45.17) x 30,000) margin
for the Flex Peak Program to be cost-effective. Please see the attachment provided for
this response that estimates the costs with and without the automatic option.
The response to this Request is sponsored by Quentin Nesbitt, Research and
Analysis Leader, ldaho Power Company.
IDAHO PO\A'ER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF- 2
REQUEST FOR PRODUCTION NO.2: The Company states thatthe approximate
cost of each device to automatically adjust equipment loads will range between $160 and
$500. Application at 6. Please describe the Company's process for recovering the
physical devices when participants drop out of the Program. Please provide analysis of
how the additional costs associated with the retrieval of the device, if any, will affect the
program's cost effectiveness.
RESPONSE TO REQUEST FOR PRODUCTION NO. 2: ldaho Power plans to
operate the Flex Peak automatic dispatch option similarly to how it operates its automatic
option for its irrigation demand response program in that devices will stay in place unless
the customer specifically asks for the device to be removed. This practice mitigates future
installation costs should the customer choose to re'enroll at some point. ln relying on this
practice in its lrrigation Peak Rewards program, ldaho Power communicates with
customers that it would be the Company's preference to leave the device in place. ln the
case of the proposed Flex Peak program, if the customer wants the device removed and
the customer installed the device themselves, the Company will request the customer
uninstall the device upon dropping out of the program. An Energy Advisor would then
retrieve the device, and this method would not add any material costs to the program. !f
the Company's representatives are utilized to installthe device, ldaho Powerwould create
a workorder with a contracted electrician to uninstall and retrieve the device. This cost is
estimated to be between approximately $200 and $400 per workorder. These potentia!
dollars would only add an estimated $2,000 per year to the total cost of the program and
are not anticipated to impact the overall program cost-effectiveness in a significant way.
The response to this Request is sponsored by Quentin Nesbitt, Research and
IDAHO PO\A'ER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF.3
Analysis Leader, ldaho Power Company
IDAHO PO\A'ER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF- 4
REQUEST FOR PRODUCTION NO.3: Please indicate the expected increase in
the realization rate suggested by peer utility consultations. Please provide any supporting
documents used as the basis for this estimate.
RESPONSE TO REQUEST FOR PRODUCTION NO. 3: Idaho Power had virtual
meetings with 4 other utilities when researching Commercial and lndustrial (.'C&1") DR
programs. During these conversations, each of the utilities described that they believed
their automated sites had more consistency in load reduction than manual sites that were
also enrolled in their programs. Specific data points or percentages were not discussed.
The Company believes the increased realization rate rationale to be likely based on the
type of Ioad C&l customers are most likely to nominate into the program under the
automatic option (such as an HVAC system). These types of systems generally have
more consistent load profiles than other variable loads customers nominate into the
program.
The response to this Request is sponsored by Quentin Nesbift, Research and
Analysis Leader, ldaho Power Company.
IDAHO PO\A'ER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF- 5
REQUEST FOR PRODUCTION NO. 4: The Company describes the following
caveat to Tariff No. 101 on page 82-1:'The Company shall have the right to accept
Participants at its sole discretion based on criteria the Company considers necessary to
ensure the effective operation of the Program.' Application at 8. Please provide answers
to the following.
a. Please explain the reasoning for this caveat;
b. Please define the criteria the Company will use to determine which businesses
are eligible for this Program;
c. Please explain how the current criteria will be publicized so businesses will know
up front whether they qualifu for the Program; and
d. Please describe a scenario in which a company would meet all publicized
criteria, and want to participate in the Program, but the Company would not allow
them to participate in the Program.
RESPONSE TO REQUEST FOR PRODUGTION NO. 4:
a. This language is present in each of the demand response programs. The language
is primarily necessary so the Company can manage total program capacity (i.e.,
not be required to enroll customers when there is not a need for additional
capacity). Other reasons the Company considers are: the 20 kW minimum load
reduction per site not being possible based on the customers past usage
information, the Company has determined it cannot get power line carrier
communication or cell communication to work at a site, the facility system
configuration is not compatible, or the electrical system configuration is not able to
be controlled with the available automatic device options. ln addition, the Company
IDAHO PO\A'ER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF.6
may determine that due to safety concerns, device availability, or contractor issues
the automatic dispatch option may not work for a particular customer and would
recommend the manual participation option.
ln the context of the newly added automated option, the continuation of this
provision will allow ldaho Power to evaluate customers during the onboarding
process and determine the best participation option on a customer-by-customer
basis. Additionally, for customers that have elected the Automatic Dispatch Option,
they can choose whether to have the Company install the Load Control Device at
no cost to the participating customer, or they can arrange directly for a licensed
electrician to instal! the device at the participating customers expense with no
ldaho Power reimbursement. Regardless of whetherthe Company orthe customer
installs the device, the Company proposes that the customer will be solely
responsible for any costs associated with the required software/hardware
integration unique to their facility or system.
b. The Company does not plan to change who is eligible for the Flex Peak program.
The program will be available to C&l customers receiving service under Schedules
9, 19, or a Special Contract Schedule. To enroll in the program the customers
must be capable of providing at least 20 kW of load reduction. The automatic
option will also be available to all customers, with the exceptions mentioned in
answer (a.) above. lf the customer meets all other requirements and wants to
participate, but the automatic option will not work for their situation, the manual
dispatch option will be recommended.
IDAHO PO\A'ER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF- 7
c. ldaho Power plans to market the automatic option with the current qualiffing
criteria listed in the tariff because the qualifications are not changing. The
Company will evaluate each customer that applies to ensure that the automatic
dispatch option is the best way for them to participate (for the reasons stated in
answer a.) so that consistent and reliable load reduction can be achieved.
d. Please see answer to (a.) above.
The response to this Request is sponsored by Quentin Nesbitt, Research and
Analysis Leader, ldaho Power Company.
IDAHO PO\A'ER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF- 8
REQUEST FOR PRODUCTION NO. 5: Tariff No. 101 at 824 establishes that
participants can elect a Manual Dispatch Option or an Automatic Dispatch Option. Please
clarify if a customer with multiple sites or buildings must choose only one option of if a
combination of both options will be possible.
RESPONSE TO REQUEST FOR PRODUCTION NO. 5: A customer with multiple
meter service locations may choose a combination of either the Automatic or Manual
Dispatch Option. The customer will select the option for each eligible meter service
location on the Flex Peak Program application when they enroll.
The response to this Request is sponsored by Quentin Nesbitt, Research and
Analysis Leader, ldaho Power Company.
DATED at Boise, ldaho, this 2nd day of November 2022
Wtriut^r^fifl0,A
MEGAN GOICOECHEA ALLEN
Attorney for ldaho Power Company
IDAHO POVVER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF- 9
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 2nd day of October 2022, I served a true and
correct copy of ldaho Power Company's Response to First Production Request of the
Commission Staff to ldaho Power Company upon the following named parties by the
method indicated below, and addressed to the following:
Commission Staff
Chris Burdin
Deputy Attorney Genera!
ldaho Public Utilities Commission
11331 W. Chinden Blvd., BIdg No. 8,
Suite 201-A(83714)
PO Box 83720
Boise, lD 83720-0074
_Hand Delivered
_U.S. Mail
Overnight Mail_FAX
FTP SiteX Emai!: [e-mail]
\**&r^J.
Stacy Gust, Regulatory Administrative
Assistant
IDAHO PO\A'ER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF- 1O
SEE ATTACHED SPREADSHEET