20090205Rocky Mountain Power Comments.pdf

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~ ROCKY MOUNTAIN
~~!!~~ORP
RECE -I~ .",'
2009 FEB -5 AM 9: 21 201 South Main, Suite 2300
Salt Lake City, Utah 84111
Februar 4, 2009
VI ELECTRONIC FILING
AND OVERNIGHT DELIVERY
Jean D. Jewell
Commission Secreta
Idaho Public Utilties Commission
472 W. Washington
Boise, ID 83702
RE: Rocky Mountain Power's Comments in Case No. GNR-E-08-04
Dear Ms. Jewell:
Pursuat to the Commission's notice of inquiry on the Energy Independence and Security Act of
2007 (EISA of 2007), Rocky Mountain Power ("RM" or the "Company") hereby submits for
filing an original and seven (7) copies of the Company's comments.
The Company's comments are responsive to the diectives contaned in Order No. 30705 issued
December 16, 2008 by the Commssion for consideration and ar limited to the four amendments
to section 111 of the Public Utilty Reguatory Policies Act of 1978 (PURP A) contaed in the
Energy Independence and Securty Act of 2007.
Very trly your,VJ~'
6aniel E. Solander (. fiSenior Attorney i
Enclosures
RECEi
Daniel E. Solander
Senior Attorney
ROCKY MOUNTAIN POWER
201 South Main, Suite 2300
SALT LAKE CITY, UT 84111
[phone]
[phone]
A.ttorney for Rocky Mountain Power
2009 FEB -5 AM 10: 04
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE COMMISSION'S
CONSIDERATION OF FOUR AMENDMENTS
TO SECTION 111 OF THE PUBLIC UTLITY
REGULATORY POLICIES ACT OF 1978
(PURPA) CONTAINED IN THE ENERGY
INDEPENDENCE AND SECURITY ACT
OF 2007.
) CASE NO. GNR-E-08-04
)
) ROCKY MOUNTAIN
) POWER'S RESPONSE
)
)
)
COMES NOW PacifiCorp, dba Rocky Mountain Power ("the Company" or
"RMP"), by and through its attorney, provides responses to the directives contained in
Order No. 30705 issued December 16, 2008. RMP submits the following Response
detailng its consideration or implementation of the four federal standards added to the
Public Utility Regulatory Policies Act of 1978 ("PURP A") by the Energy Independence
and Security Act of 2007 ("EISA").
I. Integrated Resource Planning
Regarding integrated resource planing, Section 532 of EISA of 2007 states that
"each electric utilty shall integrate energy efficiency resources into utility, State and
regional plans." The Company has been conducting integrated resource planing for
nearly two decades in par guided by the Resource Management Requirements of the
Commission. The Company files an integrated resource plan with the Commission on a
biennial basis pursuant to Commission Orders and normally fies an update to the
REPL Y COMMENTS OF
ROCKY MOUNTAIN POWER
- 1 -February 4, 2009
biennal plan between plans. Energy effciency resources are a signficant resource
considered by the Company in its integrated resource plang process. In the
Company's 2007 Integrated Resource Plan Update ("2007 IR Update") (June 2008),
energy effciency resources accounted for approximately 4.6 milion megawatt-hours
withn the preferred portfolio, up from 2.2 milion megawatt-hours identified in the 2007
Integrated Resource Plan ("2007 IRP") (May 2007). In May 2008 the Company received
approval from the Idao Public Utilities Commission to expand fuding to its Rate
Schedule 191 to approximately $5 millon or 3.72 percent for the DSM progrs
approved in Idaho in 2006, as well as to add the Energy FinAswer program, a
comprehensive energy effciency incentive program for business customers, to the
Company's DSM program portfolio. Also in 2008, the Company worked with irrgators
and regulators to expand the irrgation load management program from approximately 80
MW in 2007 to over 200 MW in 2008. The increased fuding, program set, and
irgation load management program work were all identified as actions necessar in the
pursuit of Idaho's resource contrbutions in support of the 2007 IRP Update.
The increase in energy effciency and load management tagets included in the
2007 IR Update was made possible by prelimiar work from the completion of a
comprehensive system-wide demand-side resource market assessment (June 2008). The
Company has incorporated information from ths study, resources identified in the 2007
IRP and plan update, and another yea experience rung DSM programs into the
plang assumptions and forecasts for the 2008 IRP scheduled to be fied by March 31,
2009.
REPLY COMMENTS OF
ROCKY MOUNTAIN POWER
- 2-Febru 4, 2009
Section 532 of EISA of 2007 also states that "each electrc utility shall adopt
policies establishig cost-effective energy effciency resources as a priority resource."
Modeling of energy effciency resources in the 2007 integrated resource plang process
was done by decrementing the load forecast by the 2.2 milion megawatt-hours known to
be available at that time, in effect tang these resources ahead of supply-side
alternatives. In the 2008 IRP, energy efficiency resources are based on the results of the
comprehensive system-wide demand-side resource market assessment study, and the
resources will be treated as fuctionally equivalent to supply-side resources utilzing
supply-cures. If the energy effciency resource compares favorably to other resources in
terms of cost effectiveness, customer-rate impact, and the balance between cost and risk
exposure, the resource will be selected for inclusion in the preferr portfolio.
II. Rate Design Modifcations to Promote Energy Effciency
The Company curently offers seasonal rates to residential, general service, and
large general service customers in Idaho. These rates give customers clear signals about
the appropriate cost of energy by season. The Company also offers optional time of use
rates to our residential and general servce customers. In addition, the Company offers an
irgation load control dispatch program, a renewable energy rider for small and bulk
purchases, and net metering service. We believe that these rate designs help to promote
energy effciency while mitigating bil impacts on our customers.
In addition, the Company ha filed an Application for an Energy Cost Adjustment
Mechansm (ECAM) in Idao which will give customers more curent price signals about
the changes in net power costs that occur between general rate cases. We believe that the
REPLY COMMENTS OF
ROCKY MOUNTAIN POWER
- 3 -Febru 4, 2009
ECAM will give customers more curent and appropriate price signls about the cost of
energy.
The Company has also committed as par of its next general rate case to fie a
tiered rate design proposal for the Commssion's consideration.
III. Smart Grid Investments
The Company does not consider smar grd technology presently to be matu
enough to warant Company investment and customer support of a smar grid program in
Idaho. The Company believes that national stadards and protocols need to be developed
and adopted and that a positive benefit to cost ratio needs to exist before customers are
asked to fud such a project. EISA of 2007 provides for the fuding of the National
Institute of Stadards and Technology to coordinate and develop a framework for smar
grd technology that includes protocols and stadards for information management in
order to achieve interoperabilty of smar grd devices and systems. Ths fuding is
provided for fiscal years 2008-2012.
There are several smar grd pilot progrs and projects in the developmental
stage thoughout the countr. The largest full scale projects are in Californa and Texas.
In addition, pilot programs are underway in Boulder, Colorado with Xcel Energy and
Poudre Valley REA. These pilot projects will add to Rocky Mountan Power's
evaluation of the continuing development of smar grd technologies.
The Company believes that moving forward with advanced meterig and or smar
grd investments at ths time, prior to the matuation of technologies and the finalization
of protocols and stadards, is not in the best interest of the Company or its customers.
REPLY COMMENTS OF
ROCKY MOUNTAIN POWER
- 4-Febru 4, 2009
iv. Smart Grid Information
As the Company noted above, it does not consider smar grid technology to be
presently matue enough to warant Company investment and customer support of a
smar grd progr in Idaho.
Curently the Company does not provide inormation on wholesale electrcity
prices to its customers. However, the Company does offer an optional time of day rate
and an irrgation dispatch program that provides customer incentive to use energy durng
off-peak hour.
Usage inormation is included on customer biling statements. Usage inormation
is also available to customers electronically though registered accounts accessed via the
Company's website.
Rocky Mountan Power anualy provides its customers with a wrtten notice of
sources of the power provided by the utilty by ty of generation as par of its Power
Content Label, typically included in customers March biling statement. Whle
greenhouse gas emission by fuel source information is not provided to customers, the
Company does track caron dioxide emissions of its generating resources.
V. Conclusion
Rocky Mounta Power has considered the issues identified by the four new
federal stadads and has alady implemented many of them and is monitoring the
development of smar grid technologies. The Company believes the Commission should
find that the Company's efforts meet the intent of the stadards such that no fuer
action is required in this docket.
REPLY COMMENTS OF
ROCKY MOUNTAIN POWER
- 5 -Febru 4, 2009
Respectfully submitted this 4th day of Febru 2009.
lJ~
Danel E. Solander
Senior Attorney
Rocky Mountan Power
REPLY COMMTS OF
ROCKY MOUNTAIN POWER
- 6-Febru 4, 2009
CERTIFICATE OF SERVICE
I hereby certify that on ths 4th day of Febru, 2009, I caused to be served, via E-mail, a
tre and correct copy of the foregoing Rocky Mountain Power's Reply Comments in
Case No. GNR-E-08-04 to the followig:
Kelly Norwood
A vista Utilties
POBox 3727
Spokane, W A 99220-3727
kelly.norwood(iavistacorp.com
Baron L. Kline, Senior Attorney
Idaho Power Company
PO Box 70
Boise, ID 83707-0070
bkline(iidahopower.com
David Meyer
A vista Corporation
PO Box 3727
Spokane, W A 99220-3727
david.meyer(iavistacorp.com
John R. Gale, VP- Reguatory Afairs
Idaho Power Company
POBox 70
Boise, ID 83707-0070
rgale(iidahopower.com
Ted Weston
PacifiCorpl dba Rocky Mounta Power
201 S. Mai St., Suite 2200
Salt Lake City, UT 84111
Ted. weston(ipacificorp.com
Mark Moench
Danel Solander
PacifiCorpl dba Rocky Mountan Power
201 S. Main St. , Suite 2300
Salt Lake City, UT 84111
mark.moench(ipacificorp.com
daniel.solander(ipacificorp.com
Kristine A. Sasser
Deputy Attorney General
Idaho Public Utilties Commssion
472 W. Washigton
PO Box 83720
Boise, ID 83720-0074
krs.sasser(ipuc.idaho. gov
Scott H. DeBroff, Esq.
Wal-Mar
Rhoads & Sinon LLP
One South Market Squae
PO Box 1146
Harsburg, P A 17108- 1146
sdebroff(irhoads-sinon.com
Alicia R. Petersen, Esq.
Wal-Mar
Rhoads & Sinon LLP
One South Market Square
PO Box 1146
Harisburg, P A 17108- 1146
apetersen(irhoads-sinon.com
CaeÇ~~
Coordiator, Administrative Servces