20030818Comments.pdf

Jean JewellFrom:Sent:To:Subject:Ed HowellFriday, August 15 , 2003 3:13 PMJean Jewell; Ed Howell; Gene Fadness; Tonya ClarkComment acknowledgementWWW Form Submission:Friday, August 15 , 20032 : 13 : 0 5 PMCase: IPC-E-02-Name: Pike TeinertStreet Address: 834 Harcourt RoadCi ty: BoiseState: IDZIP: 83702HomeTelephone: 208 429-9292E-Mail: pteinert~cableone. netCompany: Idaho Power Companymailinglist _yes _no: yesCommentdescription: In Order No. 29291 theissues. My comments follow each issue restated Commission seeks comment on the followingbelow.1. Should the Commission direct the Company to implement AMR on its system?Idaho Power should be directed by the Commission to implement AMR on its system. AMR is amature technology that improves delivery reliabili ty, decreases production requirementsand enhances customer value. As a production option it diminishes the need for new orpurchased capaci ty. AMR is a wise , efficient , effective and environmentally benign
addi tion to Idaho Power : s system.
The 108th Congress has approved Energy Bills in both the House and Senate that will soon
go to Conference Commi ttee to resolve differences. Each bill includes provisions for time
of use rates and advanced metering for each customer class.
Given yesterday : s massive power outage on the East Coast , renewed emphasis will likely
ensure Congress passing and the President signing this legislation. Idaho Power should
proacti vely implement AMR and not wai t until it is required by Federal legislation. Rules
and regulations that are promulgated at the Federal level will not be as sensi ti ve toState issues as those developed specifically by Idaho : s Public Utility Commission.
2. How can advanced metering enable Idaho Power Company and ratepayers to make the most offuture i S:smart grid i " transmission and distribution technology?
Based on research completed by EPRI in December 2002 (Functional Requirements for Customer
Communications , EPRI final report number 1001719) on behalf of its members , the report
indicates that metering and/ or communication technology can enable or enhance Transmission
and Distribution benefi ts in the following functions:
Y Customer Service and AdministrationY Load Management
Y Load DisaggregationY Load Profiles and Aggregation
Y Pricing
Y Distribution Automation Support
Y Integrated Resource Planning
Y Energy Services
Y Quality of Service Monitoring
Y System PerformanceY SafetyY Business Strategy and Equipment IntegrationY Meter ManagementY Meter ReadsY Meter Data ManagementY Measurement QuantitiesY Meter , data and Transactions SecurityY Disaster RecoveryY Equipment Integrity RequirementsImprovements in these areas will benefi t Idaho Power and its ratepayers and enable them take advantage of the smart grid as it continues to develop.3. As part of a Wlse investment , what features or technology should the Company employ?Wireless communication technology and advanced smart meters enhanced by continueddevelopment of robust , efficient and effective applications are the appropriatetechnologies for AMR at Idaho Power Company. Wireless technology advancements continue grow at increased rates. Coupled wi th Internet capable gateway devices that are deployedas advanced meters , Idaho Power and its customers will benefi t now and in the future.Wireless technology is currently the most prevalent form of communication technology usedfor AMR and Load Management systems.4. Under what timeframe should the Company implement AMR?Idaho Power should begin implementation of AMR immediately. Idaho Power states that it S:has been moni toring, researching and testing AMR and TOU pricing over the past 10 years After 10 years of analysis , Idaho Power should be prepared to develop, complete andrequest approval of time-of-use rates and include any rate/service fee adjustmentsnecessary to implement AMR. This analysis and the subsequent rate/ service fee adj ustmentsnecessary should be included in their announced fall 2003 , general rate increase filing.
5. How should the Company recover the costs associated wi th AMR?
Idaho Power has previously stated that in its analysis of AMR benefi ts i S:O&M savings are
derived from meter reading and its associated travel cost i . Also , in response to
request to identify and quantify all peak power/ energy reduction benefi ts that resul
from AMR and CP TOU pricing, Idaho Power has previously stated that S:this request is
beyond the scope of the current proceeding i ". Recently, Idaho Power stated that i S:The
implementation of TOU rates is outside the scope of the analysis requested by the
Commission and was not considered as part of the costs and benefi ts in the company : s
analysis i " This question , question 5., provides Idaho Power wi th the opportuni ty to
include and evaluate all benefi ts associated wi th advanced metering and communication
technology required for AMR and incorporate them in their analysis.
Beginning wi th the lengthy list of benefi ts outlined in response to question 2., above
Idaho Power should evaluate and quantify the financial and soft benefi ts of each of them.
When added to the savings from reduced meter reading and associated expense and benefi ts
from reduced peak demand and energy, the financial benefi ts of a new AMR system will
increase substantially over the simple cost reduction associated with eliminating meter
reading labor and travel costs that Idaho power has used in its previous analysis.
This costs/benefi ts analysis should become part of Idaho Power : s general rate increase
filing with the IPUC scheduled for fall 2003.
Transaction ID: 8151413.
Referred by: http: / /www. puc. s tate. id. us scripts /polyform. dll/ ipuc
Use r Add res s: 2 4 . 11 7 . 2 2 . 5 4
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