20160119_4881.pdf

DECISION MEMORANDUM
TO:COMMISSIONER KJELLANDER
COMMISSIONER RAPER
COMMISSIONER ANDERSON
COMMISSION SECRETARY
LEGAL
WORKING FILE
FROM:MARK ROGERS
DATE:JANUARY 15,2016
RE:IDAHO POWER TARIFF ADVICE NO.15-16;MODIFICATION
TO SCHEDULE 23-IRRIGATION PEAK REWARDS PROGRAM
On December 30,2015,Idaho Power Company filed a Tariff Advice with the
Commission seeking authority to modify its Electric Service Schedule 23,Irrigation Peak
Rewards Program.In this Tariff Advice,Idaho Power first proposes to consolidate
Interruption Option 1 and Option 2 into a single option that would be referred to as the
“Automatic Dispatch Option.”The consolidation would allow Idaho Power to replace
cellular-based technology with AMI technology as the cellular devices faiL.Second,
Idaho Power proposes to rename Interruption Option 3 to “Manual Dispatch Option”and
modify the current eligibility requirements to include Meter Service Points determined by
the Company to have limited load control device communication technology or
installation configuration.Idaho Power requests that the filing be processed as a Tariff
Advice and that the proposed change be effective on or before February 15,2016.
BACKGROUND
Idaho Power’s Schedule 23 Irrigation Peak Rewards Program is a voluntary load
control program currently available to agricultural irrigation service locations that have
participated in the Program in the past and receive service under Schedule 24.The
Program’s purpose is to reduce electrical load during summer peak hours by deactivating
specific irrigation pumps for a maximum of 60 hours during the period of June 15
DECISION MEMORANDUM 1 January 15,2016
through August 15.The load control events may last up to 4 hours per day and will not
exceed 15 hours per calendar week.
Currently,Idaho Power has three Interruption Options for which participants can
enroll.Option I allows only the Company to communicate with the cellular load control
device in order to activate and deactivate the pump during a load control event.Option 2
is similar to Option 1,but in addition,the customer has access to a customized website,
utilizing a cellular based technology to monitor and activate/deactivate their pump(s)
throughout the program season.Option 3 does not utilize any load control device
technology but allows the customer to manually turn off a nominated number of pumps
during a load control event.
The program underwent a pilot study in 2004,and was adopted in 2005.When
the program was expanded in 2009 to include dispatchable load control technology,
Idaho Power was just beginning to install AMI technology on its system.Until AMI
became available for load control,the Company relied on cellular-based load control
devices to deactivate pumps at participating service locations.When the Company’s
AM!technology became fully implemented,the Company began to successfully use the
AMI load control devices instead of the cellular devices.As of January 2016,roughly 16
percent of customers participating in the Program have had the cellular-based load
control devices replaced by AMI technology.
STAFF ANALYSIS
Staff has reviewed the Application and supports the Company’s proposal to
modify Schedule 23.To summarize,there are 2,776 participants in the Program of which
442 have already had AMI meters installed in place of cellular-based load control
devices.The Company proposes transferring the remaining customers to AM!meters as
the cellular-based devices fail.The Company determined that AMI technology is
unavailable to approximately 334 participants.Thus,the Company has proposed
modifying the requirements of Option 3 to extend participation to these customers under
the “Manual Dispatch Option.”Staff supports the proposal and believes it will help
simplify the Peak Irrigation Rewards Program.while reducing costs.
DECISION MEMORANDUM 2 January 15,2016
Consolidation ofInterruption Options 1 &2
In 2015 Idaho Power reviewed Schedule 23 and the number of service locations
enrolled in each of the three Interruption Options.The Company states that 95 percent of
participating service locations were enrolled under Option 1,while only 3 percent were
enrolled in Option 2 and 2 percent in Option 3.Currently,Option 2 requires a more
advanced cellular-based technology in order for customers to monitor and turn oWoff
their pump(s).Idaho Power asserts that these features have higher costs associated with
replacement installations,annual service fees and ongoing maintenance expenses.The
Company estimates that replacing all cellular devices with the AMI devices would reduce
the Program’s service and installation costs by 74 percent per device,and future
maintenance costs by 88 percent per device.
Staff inquired as to the costs of the devices and the total savings when all cellular
devices are replaced with AMI technology.At a current service and installation cost of
roughly $1,545 for cellular-based devices,and $401 for AMI control devices,the service
and installation savings could be roughly $2,288,000.With a maintenance cost of $781
per cellular device and $94 for AMI devices,the total expected maintenance savings
could be around $1,376,000;for a total of roughly $3.66 million once all cellular-based
devices are replaced with AMI technology.Staff reviewed the cost savings estimates and
believes they are reasonable.
Staff also reviewed the Demand Response Programs Settlement Agreement in
Case No.IPC-E-13-14,which set stipulations for the Irrigation Peak Rewards Program.
Under this Settlement,Idaho Power is required to continue the Peak Irrigation Rewards
Program using existing participants and equipment when possible.Staff notes that the
Company’s Application conforms to the stipulations set forth in the Settlement as
participants who are currently using cellular technology would not see any changes
immediately because the Company would not immediately remove working cellular
devices.Rather,as these devices fail,or at a time in the future when the Company
determines it is cost-effective,the Company would replace each cellular device with an
AMI device.
Furthermore.Staff notes that Idaho Power’s proposed Program modifications
were presented on November 5hh1,2015 to the Energy Efficiency Advisory Group,and
DECISION MEMORANDUM 3 January 15,2016
were vell supported.Staff believes that the consolidation of Interruption Option I and
Option 2 into an “Automatic Dispatch Option”conforms to the previous Settlement,and
is fair and reasonable.Staff further believes that combining Option I and Option 2 will
help simpli’the Peak Irrigation Rewards Program for customers and the Company,
while reducing costs associated with the program and simultaneously enhancing the AMI
network.
Modification of Option 3
Idaho Power seeks to rename Interruption Option 3 to “Manual Dispatch Option”
and modify the requirement for participation.The Company requests that qualification
for the enrollment in the Manual Dispatch Option include service locations that the
Company determines may be limited by load control device communication technology
or installation configuration.Idaho Power states that these proposed changes vill not
impact service locations currently enrolled under this option,but instead,will allow
flexibility to include other sen’ice locations making it possible for customers to
participate in the Program without the Company incurring the added costs of maintaining
load control technology.
Staff particularly reviewed the issue of customers limited by load control device
communication technology and installation configurations.These situations
predominantly include customers that lack AMI installation capabilities,and to a lesser
extent,cellular communication.These customers currently have total service loads under
1,000 horsepower and use satellite based phone technology rather than cellular devies to
participate in the Program.By modifying the requirements of Option 3,customers under
1,000 horse power that are limited by load control device communication will be able to
switch to the “Manual Dispatch Option”,allowing them the flexibility to choose which
irrigation pumps at a Metered Service Point will be interrupted during each dispatched
Load Control Event.
Staff believes it is reasonable to rename Interruption Option 3 to “Manual
Dispatch Option”and modify the eligibility requirements to include service locations that
the Company determines may be limited by load control device technology or installation
configuration.Staff believes that this will enable those customers who lack cellular
DECISION MEMORANDUM 4 January 15,2016
communication to cut costs on satellite based technology by switching to the Manual
Dispatch Option.Furthermore,as the cellular technology is replaced by AMI meters,
those customers who are under 1,000 horsepower and lack AMI installation capabilities
will have an option to enroll in the Manual Dispatch Option in the event that their cellular
based technology fails.Thus,all customer’s currently enrolled in Option 2 will be able to
remain in the Peak Irrigation Rewards Program by either switching to the “Automatic
Dispatch Option”,or the “Manual Peak Option.”
STAFF RECOMMENDATION
Staff believes proposed changes to its Schedule 23 Irrigation Peak Rewards
Program are fair and reasonable,and recommends approval of the tariff with an effective
date of February 15,2016.
COMMISSION DECISION
Does the Commission wish to approve Idaho Power’s proposed tariff changes to
its Schedule 23 Irrigation Peak Rewards Program to be effective February 15,2016?
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Udmemos/ipe_final_tariif_advice
DECISION MEMORANDUM 5 January 15,2016