Loading...
HomeMy WebLinkAbout20070816PAC to Staff 24, 32.pdf~ ~~~o ~OUNT AIN 201 South Main, Suite 2300 Salt lake City, Utah 84111 R r: ('!::. 'c"" Vb August 15 2007 ,do I I b /\ q: I 8 Scott Woodbury Deputy Attorney General Idaho Public Utilities Commission 472 W Washington Boise, ID 83702-5983 10t\! Neil Price Deputy Attorney General Idaho Public Utilities Commission 472 W Washington Boise, ID 83702-5983 RE:PAC-07- IPUC Production Data Request 18- Please find enclosed Rocky Mountain Power s Response to IPUC Production Requests 24 and 32. If you have any questions, please feel free to call me at (801) 220-4975. Sincerely, /J *'" c..(Brian Dickman, Manager Regulation Enclosures P AC- E-07 -05/Rocky Mountain Power August 15 2007 IPUC Production Data Request 24 IPUC Production Data Request 24 a. Please explain how the Idaho Irrigation Load Control program is modeled in GRID. b, Have the net power costs been adjusted to reflect the dispatchable pilot program approved in Case No. PAC-06-12? c. Have any adjustments been made to the Idaho jurisdictional loads and the irrigation Schedule 10 loads to account for the approved pilot program? d. How does the monthly peak reduction (actual and expected) for 2007 compare with 2006 peak reduction? Response to IPUC Production Data Request 24 a. The company includes the Idaho Irrigation Load Control program in its rate case by reflecting the actual hourly weather normalized loads from 2006. The loads include the actual Idaho irrigation curtailments and also include any incremental loads caused by irrigators making up for the curtailment once the curtailment restrictions are removed. The incentive payment made to participating customers is included as other power supply cost in FERC Account 557, and is situs assigned to the company s Idaho jurisdiction (refer to Page 4.11 of Exhibit 11). In responding to this request, the company discovered it also included the Irrigation Load Control program as a system-allocated resource in the GRID model in addition to the costs included in Account 557. The company will provide a revised GRID run with its rebuttal testimony that corrects this double inclusion of the program; the impact on the case will be minimal. b. No. The Idaho case was prepared before the start ofthe 2007 irrigation season. The best information available at the time the case was prepared was the Schedule 72 Idaho Irrigation Load Control 2006 Credit Rider Initiative Final Report which is provided as Attachment IPUC Production 24. c. No. d. During 2007 the company received approval to implement a pilot dispatchable load control program (Schedule 72A) in addition to the pre-scheduled curtailment program (Schedule 72). The lack of a full season s experience with the pilot program, the uncertain duration of the pilot program, and the differences between the two programs make it difficult to directly compare peak reduction expected in 2007 to that achieved in 2006. During 2006, the Schedule 72 pre-scheduled curtailment program had between 77 MW and 95 MW on a monthly basis, spilt between Monday-Wednesday and Tuesday- Thursday curtailments (refer to Attachment IPUC Production 24). PAC-07-05/Rocky Mountain Power August 15, 2007 IPUC Production Data Request 24 Preliminary results for the 2007 irrigation season indicate that the Schedule 72A pilot program has between 45 and 55 MW of dispatchable curtailment and the Schedule 72 pre-scheduled curtailment program has 50 MW split between Monday- Wednesday and Tuesday-Thursday curtailments. Please note: data for the 2007 irrigation is preliminary; verified customer counts, site counts and associated loads will be provided in the final irrigation load control program report at the conclusion of the 2007 irrigation season. (Steven R. McDougal prepared this response and is the recordholder. It has not been determined who will sponsor this response at hearing. Please contact Brian Dickman at 801-220-4975 to discuss this response. IDAHO P AC-O7- ROCKY MOUNTAIN POWER IPUC PRODUCTION DATA REQUESTS 18- TT ACHMENT IPUC PRODUCTION ROCKY MOUNTAIN POWER A DIVISION OF PAClF1CORP Idaho Public Utilities Commission 472 West Washington Boise, ill 83702-5983 RECE\\lEO 'lOnb NO~ - 2 ~"\O: Z \ I I',"iJ ,JOt. v UT\~Rf~s COMM\SS\O,\ 201 South Main, Suite 2300 Salt Lake City, Utah 84111 November 2, 2006 PAC--03 -14 Attention:Jean D. Jewell Commission Secretary Re:'Idaho 2006 Irrigation Load Control Credit Rider Program Evaluation Report PacifiCorp d.a. Rocky Mountain Power (the Company) hereby submits an original and eight copies of the 2006 Idaho Irrigation Load Control Credit Rider Program Evaluation Report. The purpose of this filing is to comply with Commission Order Nos. 29209 and 29416 and provide an annual evaluation of the Irrigation Load Control Credit Rider program. The Company does not intend to make a separate application in 2006 to change the amount of the Schedule 72 Load Control Service Credit for the 2007 irrigation season. On May 24, 2006 the Company entered into an agreement with the Idaho Irrigation Pumpers Association that the tariff amount for 2007 will equal the current amount (subject to Commission approval, Docket No. PAC-06-4). However, per program specifications, the Company will notify all Schedule 10 customers of the 2007 credit level by January 15 2007. It is respectfully requested that all formal correspondence and staff requests regarding this matter be addressed to: By E-mail (preferred):datareq uest€Yoacifi corp. com By Fax:(503) 813-6060 By regular mail:Data Request Response Center PacifiCorp 825 NE Multnomah St., Suite 2000 Portland, OR 97232 Informal questions should be directed to Brian Dickman (801) 220-4975. sin~d~A~ ,?~:g :~sl=n (p, Vice President, Regulation Enclosures A DIVISION OF PACIFICORP Schedule 72 Idaho Irrigation Load Control Program 2006 Credit Rider Initiative Final Report 23 October 2006 Table of Contents Page Background......................................,..,..........................,....,.................,.......................................,,.............".......,......... 2006 results ............,...........................................................,........,....."................................,........,.................................. 1 Cost effectiveness analyses............,......,........,...........................................................,......,.......................................... 5 2005 cost effectiveness calculation error................................,.....................................................................,.............. Load profile data.......................................,............................,...,.........................,.......................................................... Technical challenges..........................,......,.......................,......,.,....,.....................,........................,.......................,..... Measurement & Verification (M&V) processes """"""""""""""""""""""""""""""""""""""""""""""'"........... Crop type analysis..........,...................,.............................."""""""""""""""""""""""""""""""""""""....,.."........ Program enhancements under consideration ..........................................,...,.,.................."""""""""""""""""""" 16 2006 Idaho l11igation Load Control Program-Final Report Background Idaho Public Utilities Commission Order No. 29209 and Order No. 29416 in Case No, PAC-E-Q3-14 requires PacifiCorp dba Rocky Mountain Power ( the Company) prepare an annual report on the Idaho Irrigation Load Control Program (Program). Subsequent to 2003, reporting requirements include responses to the following: 1. The number of irrigation customers who were eligible to participate in the Program 2. The number of irrigation "Customers who entered into a load control Service Agreement 3. The number of irrigation customers who participated in the Program for the full three and one-half months 4. The number of irrigation customers who are not eligible to participate in the following year's Program 5. The total dollar amount of credits provided tinder the Program identified by month 6. Proposed changes and/or recommendations to improve the Program 2006 results Table One details eligible 2006 Schedule 10 sites and customers (requirement #1)1. Table One also contains counts of customers and sites that entered into an actual load control contract (requirement #2), Details for Program years 2003, 2004 and 2005 are provided for comparison. The data presented in Table One reflect the number of irrigation customers and sites that participated in the Program for the full three and one-half months (requirement #3). In 2006, 20.1 % of total available sites and 23.3% of the total available customers participated in the Program. There are zero customers NOT eligible to participate in 2007 (requirement #4). Table One Schedule 10 Eligible & Full-Year Participating Sites & Customers 2003 Actual Participants 2004 Actual Participants 2005 Actual Participants 2006 Actual Participants Eligible 2006 Counts Customers NOT eligible to participate 2006 Nom: ba~d on 15 Sepmmher re~ Partici ant Sites 401 734 065 931 636 N/A Participant Customers 207 340 489 478 044 Unadjusted monthly participation credit amounts issued to 2006 Program participants are presented in Table Two (requirement #5). The total Program participation credits ($925 577.33) represent an 8.9% increase over 2005 credits. Table Two further presents the total amount of resource under contract at the time of credit issuance. Table Three presents a comparative analysis of credits issued for the 2003, 2004, 2005 and 2006 Program years. Here again, 2006 values are unadjusted. The reader should note that the Commission approved a ==21% increase in 1 Data are reported as of 15 September 2006. This notation is important as Program participants and subsequenUy loads change throughout the irrigation season as Program participation status may change as a function of agri-business, weather, crop type and/or equipment vagaries. Wherever possible and based on what the Irrigation Management Team has detennined to be the most understandable way to communicate quantitative Program demographics and impacts. reporting date may change. Accordingly, and throughout this report the(jate for the specific quantitative result will be noted. 2006 Idaho Irrigation Load Control Program-Final Report participation credits over the 2005 Program year. Despite increased participation credits there was no corresponding increase in participation sites. In fact, participation marginally waned (9.9% decrease in avoided MW;12,58% decrease in the number of participating sites; 2.25% decrease in the number of participating customers)2 Program management has speculated as to the reason for this trend including the following: 1. Commodity prices for agricultural product crop selection2. Water soil moisture considerations 3. 2005 premature timer failures While it is not entirely clear, the fact of the matter is that the Irrigation Management Team can offer no definitive explanation for the lower-than-expected-paTticipation. Meetings with growers were planned and executed to assess the whys and wherefores of grower participation with regards to the load control initiative, Moreover, and during the meetings with growers, consideration was given to discussing the potential use of a fully duplexed control technology that would permit dispatch options at the discretion of the Company (similar to the 2001 Program design). The result of these discussions and the pilot testing of the new control technology are discussed in the Program Enhancements Under Consideration section. Further, it should be noted that the 2006 Program year-end report statistics are based on the Program transactional database. The database offers a 'snapshot' in time and does not take into consideration Program participants who may have elected to discontinue participation prior to 15 September. Hence, the statistical information may, if anything, understate Program impacts (particularly, avoided kW). For example, at the conclusion of the sign-up phase and the beginning of the dispatch period (1 June) the database recorded 50.8 MW firmed scheduled resource. At the conclusion of the. irrigation season the database indicated an average peak avoided MW of47., a difference of3.7MW. Table Two 2006 Participation Credits x Month Credits kW Under Contract June $240 705. 82,652. July $317,825. 100,131.8 August $288,371.66 95,321. September $78,674. 127. Table Three 2003-2006 Comparative Participation Credits Issuance Year 2003 2004 2005 2006 Total Participation Credits Issued $277,583. $406,002. $842,666. $925,577. 2 Comparisons were based on the peak average difference as of 15 September. 2006/daho Irrigation Load Control Program-Final Report Table Four introduces unadjusted 2006 Program costs. For years 2003,2004 and 2005 Program costs are represented for comparative purposes. During 2006 100% of sites that participated in the Program during 2005 were visited to inspect equipment and identify faulty timers. As discussed in the Technical Challenges section of this report, during 2005 the Program experienced a high frequency of timer failure, The source of the problem was identified as a flawed board design. Working closely with the manufacturer (Grasslin, a German subsidiary of GE) and the local distributor (Consolidated Electric Company (CED); Logan, UT) timer change-outs were negotiated for the 2006 season. This change-out practice had a dramatic effect on customer service as the~e was less than 10 customer service calls (or c::: 1 % of total timers installed) associated with equipment failures during 2006. Table Four Comparative Load Control Program Costs 2003, 2004, 2005 & 2006 2003 Costs 2004 Costs 2005 Costs 2006 Costs Cost Category (April '03-Sept '03)Oct 'O3-Sept 'Oct 'O4-Sept 'Oct 'O5-Sept ' Administrati~~- support $9,613.$1,665.$851,$194:60 Program evaluation $2,135.43 $8,369.$377.$0. Field Db admin. expenses $250,222,$239,807,$326,061.$330,802,ijQ Participation ~re(lits $277,583.$410,325.$842,666.80 ,$925,577. Program management $10,992.$55,036.$54,826.$ 42 554. Reporting $351.79 $1,940.$0.$0. Total Program costs -$550,900.$717,143.$1,224,783.$1,299,128. Note: 2003 costs over 6 month period; subsequent Program-year costs are calculated over a 12 month period Table Five provides avoided kW statistics and participation site counts based on participation option-(again note: data are current as of 15 September). A couple of observations are noteworthy. First, the three hour option was not a popular offer. The Irrigation Management Team met with growers and learned thatthe inconvenience and associated labor of having to accommodate a three-hour interruption was not offset by the participation credit. This was particularly noteworthy with larger growers, Nevertheless, the three hour dispatches were again important in demonstrating 'load shaping' capabilities. If modeling being undertaken by PacifiCorp s Commercial & Trading (C&T) organization shows that the 'load shaping' capabilities are sufficient to result in additional resource value, further enhancements in Program design may be warranted. For example. a pricing differential could be offered to growers to gain additional participation for a three-hour option. Bottom line, the reader should be cautioned to not unduly dismiss the low participation in the three hour blocks, It may be that these particular options have significant and measured value to the Company. Second, the six hour dispatch blocks were, by far, the most popular option, representing 91% of total Program participation. 2006 Idaho Irrigation Load Control Program-Final Repod 3 - Table Five Program Impacts by Participation Option Participation Site June Avoided July Avoided Aug. Avoided Sept. Avoided tion Ct. I MW 2-8pm 411 35,708.557.605.34,931, I TTH2-8pm 437 35,151.6 43,869.41,314.36,016. II MW3-6pm 895.957.939.835. II MW4-7pm 268.1,495.1,417.818. II TTH 3-6pm 395.597.589.541.1 II TTH 4-7pm 631.789.656.453, III MWTTH 3-6pm 458.666.632.579. III MWTTH 4-7pm 699.825.710,682.4 IV M 2-8pm 358.052.996,850. Totals:931 77,568.95,811.7 90,860.709. Note: data reported as of 15 September Table Six transposes the data presented in Table Five into dispatch schedules. Table Six indicates the avoided kW by month, control day (Tuesday Thursday) and by hour. Here also the reader should take into consideration that Program participants who discontinued participation prior to the 15 September time horizon are NOT reflected in these data. Hence these data understate the avoided kW that was actually realized at points earlier in the irrigation season. Table Seven mirror images data presented in Table Six with the exception that Table Seven reflects the Monday Wednesday control period. Table Six 2006 Avoided kW by Month, Tuesday Thursday Ctrl. Day & Hour Hour Avoided kW JUNE TuesdaylThursday Avoided kW by Hour 2:00-2:59 3:00-3:59 4:00-4:59 5:00-5:59 6:00-8:59 35,151.6 36,005.8 37,337.5 37,337.5 36,483. 7:00-7:59 35,151.6 Hour Avoided kW JULY TuesdaylThursday Avoided kW by Hour 2:00-2:59 3:00-3:59 4:00-4:59 5:00-5:59 6:Q0.6:59 43,869.5 45,133,8 46,748.7 46.748,7 45,484. 7:00-7:59 43,869. Hour Avoided kW AUGUST TuesdaylThursday Avoided kW by Hour 2:00-2:59 3:00-3:59 4:()Q..4:59 5:00-5:59 6:0Q.;6:59 41,314.0 42,535.2 43,901.6 43,901.6 42,080. 7:00-7:59 41,314. Hour Avoided kW SEPTEMBER TuesdaylThursday Avoided kW by Hour 2:00-2:59 3:00-3:59 4:00-4:59 5:00-5:59 6:00-6:59 36,016.9 37,137.0 38,273,1 38,273.1 37,153. 7:00-7:59 36,016. 2006 Idaho Irrigation Load Control Program-Final Report Table Seven 2006 Avoided kW by Month, Monday / Wednesday Ctrl. Day & Hour Hour Avoided kW JUNE MondaylWednesday Avoided kW by Hour 2:00-2:59 3:00-3:59 4:004:59 5:00-5:59 6:00-6:59 35.708.2 37,062.8 39.031.1 39,031.1 36,408. 7:00-7:59 35,708, Hour Avoided kW JULY MondaylWednesday Avoided kW by Hour 2:00-2:59 3:00-3:59 4:004:59 5:00-5:59 6:00-6:59 43,557.7 45,182.0 47 503,1 47 503.1 44,383. 7:00-7:59 43,557. Hour Avoided kW AUGUST MondaylWednesday Avoided kW by Hour 2:00-2:59 3:00-3:59 4:004:59 5:00-5:59 6:00-6:59 41,605.9 43,177.6 45,304.7 45,304.7 42,316. 7:00-7:59 41,605. Hour Avoided kW SEPTEMBER MondaylWednesday Avoided kW by Hour 2:00-2:59 3:00-3:59 4:004:59 5:00-5:59 6:00-6:59 34,931.9 36,346.1 37,847.1 37 847.1 35.614. 7:00-7:59 34,931. Cost effectiveness analyses Based upon the cost and avoided MW values above together with the $/kW-yr avoided as provided by the 2004 IRP (and used in 2005 year end computations), cost effectiveness calculation were prepared for each of the four standard utility industry tests: 1. Total Resource Cost (TRe) 2. Utility 3. Ratepayer 4. Participant The Program cost-effectiveness analysis is based on the ratio of the present value of the Program s benefits to costs and the net benefits (benefits minus costs), discounted at the appropriate rate for the various benefit/cost testS.3 The benefits are based on the calculations as defined by the Capacity Expansion Model (CEM) and reported in the 2004 Integrated Resource Plan (IRP)4. The CEM selection of Schedule 72 at$27.19/kW-yr was based on 2003/2004 costs to deliver the Program. Costs used in these calculations include administrative costs, contractor (field technician and database design / administration), participant credits, and associated equipment costs. The participation credits are not included in the Total Resource Cost (TRC) test because they are a transfer payment from the utility to the participants. The cost effectiveness of the Program was calculated by Quantec using a simplified spreadsheet analysis. This analysis multiplies average demand reductions for the June, July and August period as a result of customers participating in the Program, by the estimated value of avoided demand noted above. Again, this value is $27.19/kW-yr. This value is multiplied by 10% to account for the effect of line losses, resulting in a cost effectiveness calculation value of $29.91/kW-yr. 3 Note that no discounting of costs or benefits was required in this analysis since all costs and benefits occurred in 2006. 4 Chapter 8. p. 166. Table 8. 2006 Idaho Irrigation Load Control Program"Final Report - 5- Based on data from the Program in 2003 and 2004, PacifiCorp and Quantec examined whether energy savings, hence revenue losses, should be included in the analysis, This analysis showed that energy use is 'shifted' rather than 'avoided' hence zero energy savings were accrued for the Program and lost revenues are not included as a cost and energy savings are not applicable as indicated above, Accordingly, the benefits for the cost-effectiveness analysis are based on capacity savings alone and are presented in Table Eight: 2006 Cost Effectiveness Analyses. As shown in Table Eight, the Schedule 72 passes the TRC Test. The Program also passes the Participant Test since the participant incurs no costs. As a result, the benefiUcost ratio would be infinite for the Participant Test and the value is indicated as 'NIA' in Table Eight. Table Eight 2006 Cost Effectiveness Analyses Test Benefits Costs Net Benefits Benefit/Cost Ratio TRC $1,246,330.$374,096.$872,234. Utility $1,246,330,$1,299,673.($53,342.97) Ratepayer $1,246,330.$1,299,673.~$53,342.97) Participant $925,577.$0.$925,577.N/A 2005 cost effectiveness calculation error In the course of preparing 2006 cost effectiveness analyses it was discovered that the Company had inadvertently made two errors in the 2005 analysis. First, the $/kW-yr. value for a 'fully dispatch able' resource was mistakenly selected instead of the value for a 'firm scheduled forward' resource. The 'dispatchable' resource $/kW-year is $58.35 vs. $27,19 for the 'scheduled firm' resource. Second, in performing the.calculations the units were mistakenly transposed. Instead of calculating cost effectiveness benefit stream on the basis of $/kW-yr they were.calculated on $/MW-yr. In the 2005 Year-End Schedule 72 Report cost effectiveness values were reported as those indicated in Table Nine (below). These errors were corrected and cost effectiveness calculations recomputed. The results of these analyses are presented in Table Ten. Noteworthy is the change in TRC values. In 2005 the TRC was reported as 2.94. The corrected TRC value for 2005 is 3,81. a difference of 0.87. Table Nine Original Values Reported in 2005 Cost Effectiveness Analyses Test Benefits Costs Net Benefits Benefit/Cost Ratio TRC 124,284 $382,117 $742,167 ".- Utility 124 284 $1,224,784 $ (100,499) .""----.--..---.-. Ratepayer 124,284 $1,224,784 $ (100,499) ---" Participant $842,667 $ 842,667 N/A 2006 Idaho Irrigation Load Control Program-Final Reporl 6 - Table Ten Corrected 2005 Cost Effectiveness Analyses Test Benefits Costs Net Benefits Benefit/Cost Ratio TRC $1,455,484 $382,117 073,367 Utility $1,455,484 $1,224 784 $230,700 1.19 Ratepayer $1,455,484 $1,224,784 $230,700 1.19 Participant $ 842,667 $842,667 N/A Load profile data Throughout the control period, Company SCADA data were collected and used in preparing impact analyses. Transmission Circuit Breaker #67 (CB-67 (Big Grassy)) aggregates four distribution substations (Hamer,Sandune, Camas and Dubois) which were known to have a significant number of Program participants, SCADA values were taken and logged at 120 second intervals. Log files from CB.67 were culled, data manipulated and subsequently plotted for the July August period. A pivot table was prepared and data averages for day-of-week as well aster control vs. non-control periods were also calculated. Illustration One (Schedule 72 Idaho Irrigation Load Control-Average Daily Load CuNe: Control VB. Non-Control Periods for July August (Ce 67-Big Grassy) depicts (1) the average for all control days (Monday through Thursday, inclusive) and (2) the average for all non-control days (Friday through Sunday, inclusive), In addition to the load control dispatch, what is noteworthy is the load shifting effect as depicted in the difference between control and non-control days particularly during the non-dispatch hours. The reader will note that this 'gap' is wider in the evening and early morning hours. It is hypothesized that this trend in the 'gap' is a function of growers scheduling irrigation turns to minimize the effects of moisture loss resulting from transvaporation which, oh:ourse, is greater in the heat of the afternoon. Further note that the 'gap' narrows in the afternoon and in early evening hours. 2006 Idaho Irrigation Load Control Program-Final Report - 7- lIiusiration One Schedule 72 Idaho Irrigation Load Controi-lweiage Daily Load Curve: Control vs" Non-Contro: Periods for July & August (CS 57-Big Gr2ssy 25" ,. 2M ~5" 10" limo 124 h,," I-cut Do~ (More Th) -An Non-"'" Day-. (FrlI , SaL,Suo,) I Illustration Two (Schedule 72 Idaho Irrigation Load Contiol-Daily Load Curve: Control Average Control Dispatch Schedule (MlWvs. TTH) Averages (CB 67-Big Grassy)) plots Big Grassy 120-second interval load data by the two principle control periods (!VIfW and TfTH). The overall average for all control days during the 06 July/August period is also plotted in Illustration Two" Highlighted is the six-hour dispatch block of the 'Dispatch Event'. 2006 Idaho Irrigation Load Control Program-Final Report - 8- IIlusu-aiion Two Schedule 72 idaho Irrigation Load Control-Daily Load Curve: Control Average & Cantro: Dispatch Schedule (MNV vs, TTH) lwerages (CB 57-Big Grassy) lime (2.4 h... i-A,,!:" McnlWe1J CI~ Days -A,,!:, T...,,'ThurCtrI Do,.. -AVO All Clo" DaY" I Illustration Three (Schedule 72 Idaho irrigation Load Control-Daily Load Curve: Individual Control Day-or-Week Overalf Average Control Days) plots Big Grassy 120-second intervalloaddata"by individual day-of-week (ctrl days). Average daily control plots are also included in Illustration Three. Highlighted is the six-hour dispatch block and the impacts as a result of the 'Dispatch Events . Tuesday recorded the greatest avoided demand than any other dispatch day. This finding was rewarding as, on average, the Company experiences the greatest demand on Tuesday. The reader should note that while the Company works hard to balance dispatch loads across all dispatch days, there is equal attention to accommodate grower preference 'for a particular dispatch option. 2006 idaho inigaiion Load Control Program-Final Report Illustration Three Schedule 72 idaho Irrigation Load Control-Daily Load Curve: Individua! C~mtrol Day-of-Week & OveraJ: ,Average Control Days(CB 57-8i9 Grassy 10" /213 1'15/617/819/10/,,1'2/'3114/15/16/17/18 time (24 h". , -" Monde!, - - " - , ..esaay - - . " - Wednesdey "- - " - Thursday -A,-,"" MonIWeO -A,'I:" .uelThur -Ave" All Clrt Days Illustration Four (Schedule 72 Idaho Irrigation Loaa' Control-Daily Load Curve: Control Average vs. Non-Control Days (Ca 67-Big Grassy)) plots Big Grassy 120-second interval load data by (1) individual non-control day-or-week, (2) average for all norl-control days and (3) the average for all control days. Highlighted is the six-hour dispatch block and the resulting impacts of norl-control days" 2006 idaho irrigation !.oad Contro! Program-Final RepoIt 10 lIiustration Four Schedule 72 Idaho irrigation Load Contro!-Daily Load Curve: Contro! Average vs" Non-Contro! Days (CS 67-Big Grassy) t;m. (24 hIS. " Sun"a, - - " - - rriOay " - - - " Salumay Non-Clrt,Day AVO,Cllt Day AVO" Illustration Five (Schedule 72 Idaho Irrigation Load Control-Daily Load Curve: Total PacifiCorp Hourly Idaho Load (July) Estimated Impact of Schedule 72) plots the total Company average hourly interval load data for the month of Julys. Also plotted is a 44MW decrement (estimated average avoided MW generated as a function of Schedule 72 across the 6 hr dispatch block). While Schedule 72 accounts for a measured 'dip' in the load profile, the Idaho load even without Schedule 72 would naturafly be reduced in the afternoon hours (areas shaded in striped tan). The reason for this is that growers prefer to avoid irrigating in the heat of the day to minimize soil moisture loss as a function of transvaporation. 5 Note: at the time of the preparation of this report data are nof yet iully adjudi::ated ior F"RC reoorting; nevertheless it is not anticipated there will be measured deviafions iTom what is indicated in Illustration Five 2006 Idaho Irrigation Load Coniro! Program-Final Report 11. Illustration Five Schedule 72 Idaho Irrigation Load Control-Daily Load Curve: Total ?acifiCOrD Hourly idaho Load (July) & ::stimated Impact of Schedule 72 59D ~ SDD 58D 570 560 =50 t;me (24 h'-I !-TOL JD July Load Profile I T ec:hnic:al challenges During the 2005 irrigation season, field technicians experienced an unusually high frequency of timer malfunctions. Upon making this discovery a conference call was made between the Load Control Management Team, field technicians, Consoridated Electrical Distributors (the distributors through which the timers are purchased) and the clock manufacturer Grasslin (U.S. headquarters in NJ)6. Grasslin s U"S. Engineering group requested and was provided with a half of dozen of the failed units. At first, their evaluation was inconclusive other than that the batteries had clearly failed. At the time of the preparation of the drafting of the 2005 year-end report their European counterparts were similarly unable to preciseiy pin-point the cause of batiery failure. Additional analysis was conducted during the early winter. Around the first of the New Year the principal board designer was contacted and a fOok:aUS8 analysis prepared" It turned out that the cause of the failure was a miscalculation on the circuit board used in the timer as to the amount of Amperes drawn on the battery. That is, the failed board design exceeded the (Amp-hour (Ah) rating) of the battery itself. Changes in the board design were made to correct the problem and no cost replacement units provided to Rocky Mountain Power for t'1e 2006 Program season. 6 Gres:sun is a European timer manufacturer who was acquired by GE in 2002. 2006 Idaho Irrigation Load Control Program-Final Report - i2- With new equipment, but without knowledge of the status of each of the field installed units, a decision was made to visit and assess each of the installed timers. Accordingly, Program technicians were instructed to test and replace, where necessary, each unit. With (1) more than 1,300 individual timers, (2) an uncertain and sporadic delivery date of the re-designed boards, (3) a dynamic Program participation customer base, (4) field technician scheduling optimization, (5) weather vagaries and (6) only a limited installation window a re-drafting of field logistics and database modifications were required to meet the scheduled Program start date. Accordingly, some additional Program costs were incurred in juggling the logistics. However, it turns out that through the cooperation of end.use customers, committed field installers, a database administrator and the Company s Irrigation Hotline management staff, total Program costs ended up being within anticipated 2006 budgets. Measurement & Verification (M&V) processes Consistent with the previous three irrigation seasons, field technicians prepared random, unannounced site visits for the purpose of ensuring the integrity of timer performance and the absence of fraud. Five timer and timer-related parameters ((1) tape seal, (2) meter lock, (3) battery, (4) clock calendar and (5) pump panel) were considered in the evaluation. M&V technicians were also asked to confirm the presence of PacifiCorp Site ID stickers for inventory purposes. Where it is suspected there were variances in anyone or multiple above-defined components field technicians were required to indicate said variances in the database and to the Irrigation Load Control Management Team for adjudication. The results of the 2006 M&V activities are indicated in Table Eleven. In addition, there was one site reported to the Irrigation Load Control Management Team for adjudication but in this instance, evidence pointed to a field installation error, not end-use customer fraud. Table Eleven Results of the 2006 Measurement & Verification QA Parameter SitelD Sticker Seal Pum Panel Meter Lock Clock Calendar Batte Ctof Failures Ct. of Units Inspected 144 144 144 144 144 144 Percent Failure 28.50% 20% 50% 70% 70% 00% Crop type analysis As part of the 2005 year-end report the Idaho Commission requested that the Company prepare analysis of avoided loads by crop type for the 2006 season. This analysis is somewhat problematic as a majority of field installations occur in January, February and March prior to when a grower has made a final decision on crops and prior to planting. Nevertheless, field technicians either inquired of the grower as to crop type or could identify the emerging crop himself (in the case of late-in-season installs). Table Twelve: Known Site Estimation of Crop Type Site 2006 Idaho Irrigation Load Control Program-Final Report 13 - Avoided kW presents the results of these field data gathering efforts7. The avoided kW values were calculated by taking the full summer (1 June through 15 September) average for each of the identified sites and summing those avoided kW values by crop type; Table Twelve Known Sites Estimation of Crop Type x Site & Avoided kW Crop Type No. of Sites grain ~39hay 378spuds 186 _._._ p"asture ~~- rass "- corn ----9.olf courses sodtrees canal . grain/potatoes ~_. recha~ potatoes/corn Totals 1,153 Tot. Av . kW 363. 442. 24,400. 992. 273. 024. 124. 419. 76. 366. 257. 13. 292. 123,047. Despite being estimates, these data indicate that Program participation is largely limited to 'field' crops. 'Row' -crops, particularly potatoes have not and do not participate in the Schedule 72 initiative. Moreover, the data clearly illustrates an opportunity to grow Program participation among potato growers. Additional consideration of this finding is further discussed in the Program Enhancements Under Consideration section. Tab/e Thirteen: 2006 Program Participant Estimation of Crop Type Site Avoided kWpresents field installer estimates of only 2006 Program participant crop types. Again, these are estimates and the same constraints exist with these data as referenced with Table Twelve. Accordingly, attempts to synch-up avoided MW as reported in Table Twelve to reported Program totals should be avoided. 7 Note: these estimates represent infonnation about ALL known sites in the PacifiCorp service territory whether the site was participating in the 2006iniliativeornol , 2006 Idaho Irrigation Load Control Program-Final Report 14 - Table Thirteen 2006 Program Participant Estimation of Crop Type x Site & Avoided kW Crop Type grain hay spuds pasture ras ~_- com golf courses sad trees canal .Jjrainlpotatoes potatoes/com recharge Totals No. of Sites 360 315 894. Tot. Av . kW 44,309. 31,912. 13,131. 612. 065. 268. 122. 419. 76. 366. 257. 292. 13. 95,847. Table Fourteen: 2006 Program Participant Estimation of Crop Acreage x Crop Type presents field installer estimates of only 2006 Program participant crop types x acreage. Here again, these values represent estimates and the same constraints exist with these data as referenced with Table Twelve and Thirteen. Table Fourteen 2006 Program Participant Estimation of Crop Acreage x Crop Type Crop Type grain hay spuds pasture com grass grain/potatoes sad golf courses potatoes/corn trees Totals Total Acres 64,026 50,623 13,970 644 2,460 534 200 560 300 300 121 138,737 2006 Idaho Irrigation Load Control Program-Final Report 15 - Program enhancements under consideration Over the course of the three years that Schedule 72 (Irrigation Load Contro~ has been available to Rocky Mountain Power's Schedule 10 (APS) customers, the Irrigation Management Team has attempted to consider and implement operational changes to (1) enhance delivery I (2) improve efficiencies, (3) provide for greater data integrity / accuracy and (4) grow customer participation, The 2006 irrigation season is no different. In 2006 the Irrigation Management Team piloted a new control technology. 25 new control technology units were field tested at 14 customer sites. If, it was reasoned, the results of the field test proved successful then additional changes could be considered to one or more of the aforementioned objectives to further improve Program performance. Moreover, a successful trial could mean the technology would be considered for implementation in the 2007 irrigation season. The information that follows is a summary of the pilot background, objectives, customer assessments and anticipated benefits. Background Previous year failures with the electronic timers has created and/or contributed to (1) increased field maintenance costs, (2) customer dissatisfaction / frustration, (3) lower than expected Program participation, and (4) administrative overhead / burden. Beginning in the late fall 2005 and throughout the winter, 2006 the Irrigation Management Team began to identify and investigate altemative control technologies. Two technologies were bench tested and one (M2M Communications, Boise, 10) was selected for further consideration and piloting during the 2006 irrigation season. Throughout the 2006 irrigation season 25 sites (14 customers) participated in testing the fully duplexed (cellular / satellite) M2M pump/pivot control technology. M2M provides the underlying remote control equipment to Valley Irrigation the world's most popular and largest agricultural pivot manufacturer. This particular product line (remote pivot control) has beerJ available for five years and, according to Valley, is one of the more popular options to their base equipment. Moreover, the equipment's durability has received a favorable endorsement as a function of little / no reports of failure / malfunction during the five years it has been in the fields. The version of the control equipment tested in 2006 was based upon and nearly identical to that used by Valley Irrigation, Underlying objectives It was anticipated that the M2M technology would lower the recursive field costs and provide a platform for additional agri-business offerings. These new offerings would create operational efficiencies and improve performance reliability, By so doing, it was hypothesized that a value proposition could be struck that would address agri-business practices important to growers thereby capturing additional participation. Driving much of the thinking behind the pilot was a bias towards potato growers and the need to capture their participation if the Program were to increase in volume. Moreover, the offering could move the Load Control Program beyond a simple exchange of participation credit for shifted load. That is, growers could be provided with additional dispatch-options for growers. This approach would also eliminate the stranded equipment assets currently incurred as a function of crop rotations. Ultimately, and over time, the M2M equipment would replace the current solid state Grasslin timers. 8 As reported by equipment distributors, customers and Yalley s own internal statistics. 2006 Idaho Irrigation Load Control Program-Final Report 160 Equipment benefits / costs AQ additional benefit of the M2M equipment is the elimination of M&V as the new control technology provides an authoritative log of pump activity. But perhaps most important is the benefit of being able to remotely query the unit and test operational effectiveness. The new equipment is solid' state design so there are no moving parts or battery to keep date/time in synch as all intelligence has been migrated to the server to which the field unit communicates, The grower has improved and increased flexibility in managing equipment to meet their agri-business requirements as all commands can be managed either through the Internet or via standard telephony (cellular or traditionallandline). Older RF controllers used in the past often ended up being disconnected from the system due to breaking of antennas or coffee can shields. It is not anticipated that the M2M technology will experience this sort of either active or passive sabotage because the grower now, operating his irrigation equipment through the M2M technology, has a 'vested interest' (both operational and economic) in the equipment's effective operation. The down-side of this technology is (1) capital and (2) recursive air time communication (satellite / cellular) charges. Recursive air time communication costs only occur during the season and their impact is = $7 per site per month. The cost of the unit itself is more than twice the standard Grasslin timer currently in use. However, this is somewhat misleading. Evaluation of current and past budgets suggests that recursive field costs incurred by one-way technologies (or in the case of the Idaho program Grasslin timers) have added substantial to the overall base costs for these technologies. These un-anticipated costs have had a negative impact on Program performance. Moreover, timer failure has had a negative effect on customer service. Based on revised proforma calculations taking into consideration the use of the M2M equipment, life-cycle and maintenance costs, the M2M equipment would be more cost effective than the-current Grasslin timer' technology. For example, current Grasslin timer technology costs E= $315 per site9 and due to the lack of reliability of the timer the Irrigation Management Team has determined that each site configured with a timer MUST be visited each year. This decision has been made to maintain appropriate and reasonable levels of customer service and to ensure grower participation in the Program does not further erode. Factoring in that =30% of the participating sites require two or more timers + an annual site visit + troubleshooting at .05% of the total population the M2M equipment at =$570 per site break even is less than one control season, Pilot results With the exception of a single unit which appeared to fail as a function of installation error the M2M equipment operated according to design specifications. The Irrigation Management Team received a number of anecdotal comments from customers indicating their surprise and pleasure in being notified when the status of the pump changed as a function of a power interruption or lightning. 9 Note that == 30% of the sites require lwo or more timers. This situation occurs when a grower does not have either a pressure switch or a low voltage control connection belween the pump and the pivot. In these instances the cost to rontrol that site is roughly doubled or $600 per site. 2006 Idaho Irrigation Load Control Program-Final Report 17 - Modeling Currently the Company s Commercial & Trading (C&T) organization is performing cost effectiveness modeling assuming the installation and use of the proposed technology as a fully dispatchable solution. As of the preparation of this report. the results of these analyses are not yet available. However, when these data become available and if it is determined that a significant and measured change to the Credit Rider Initiative could be implemented, the Company will bring its recommendations to the Commission for consideration. 2006 Idaho Irrigation Load Control Program-Final Report 18. PAC-07-05/Rocky Mountain Power August 15 2007 IPUC Production Data Request 32 IPUC Production Data Request 32 Please provide transmission costs associated with qualifying facilities referenced on page 5 in Company witness Bennion s testimony, along with any additional costs included in this rate filing, Please list the transmission costs by QF specifying the location of each QF. Response to IPUC Production Data Request 32 Pursuant to PURP A guidelines and state commission policies, QFs are generally required to pay the utility most or all costs required to interconnect their projects to the utility s transmission system. Transmission upgrades which principally improve service quality, reliability, and delivery of power to meet general customer load requirements may be exceptions. During the test year in this rate case, the company did not upgrade any qualifying facility interconnection requirements in the generation interconnection or transmission project queue. (Douglas N. Bennion prepared this response, is the recordholder, and is expected to sponsor this response at hearing. Please contact Brian Dickman at 801-220- 4975 to discuss this response.