20030221Comment.pdf

Jean JewellFrom:Sent:To:Subject:Ed HowellFriday, February 21 2003 7:16 AMJean Jewell; Ed Howell; Gene Fadness; Tonya ClarkComment acknowledgementWWW Form Submission:Friday, February 21 , 200315:30 AMCase: IPC-E-02-Name: Pike TeinertStreet Address: 834 Harcourt RoadCi ty: BoiseState: IDZIP: 83702HomeTelephone: [phone]E-Mail: pteinert~cableone. netCompany: Idaho Power Companymailinglist _yes _no: yesCommentdescription: 1) Idaho Power s Application for Approval of Tariff Schedule 81Residential Air Condi tioner Cycling Pilot Program proposes to use funds collected from allrate payers under Idaho Power ' Schedule 91 , Energy Efficiency Rider which "is designed fund the Company s expendi tures for the analysis and implementation of energy conservationprograms.The Residential Air Condi tioning Pilot Program proposed by Idaho Power statesthat the program is a "dispatchable load control program . It also states , "This programis a dispatchable load control program that attempts to manage load , not energy . Energyefficiency and conservation programs are focused on energy (kWh) management. Load controlprograms are significantly different in that they are focused on peak load , demand (kW) ,control. The following explanations of these two program categories from NARUC and the DOE
help provide clear distinction between them.
DOE
Conservation program: A program in which a utility company furnishes home weatherization
services free or at reduced cost or provides free or low cost devices for saving energy,
such as energy efficient light bulbs , flow restrictors , weather stripping, and waterheater insulation.
Load control program: A program in which the utili ty company offers a lower rate in return
for having permission to turn off the air condi tioner or water heater for short periods of
time by remote control. This control allows the utili ty to reduce peak demand.
AR U C
Energy Efficiency: Using les s energy / electrici ty to perform the same function. Programsdesigned to use electrici ty more efficiently -- doing the same wi th less. For the purpose
of this paper , energy efficiency is distinguished from DSM programs in that the latter are
utili ty-sponsored and -financed , while the former is a broader term not limi ted to any
particular sponsor or funding source. "Energy conservation " is a term which has also been
used but it has the connotation of doing wi thout in order to save energy rather than using
less energy to do the same thing and so is not used as much today. Many people use these
terms interchangeably.
These distinctions are generally accepted by the electric energy industry. It is clear
that use of Idaho Power s Schedule 91 funds for Idaho Power s Residential Air Conditioner
Cycling Pilot Program would be a misuse of Schedule 91 funds. To address this problem , the
IPUC could choose to amend Energy Efficiency Rider , Schedule 91 to allow use of theproceeds to fund peak load control programs as well as energy conservation programs.2 )In Case No.IPC-E-02-& IPC-E-02-, Order No. 29026 the IPUC stated:Furthermore , Idaho Power shall consul t wi th the Energy Efficiency Advisory Group regardingthe need to ini tiate a comprehensive DSM study of the IPC service terri toryRelative to the priority for DSM funds to identify: (1) cost effective DSM opportunitiesin each customer class; (2) estimated costs to fully fund these opportunities; and (3)opportuni ties for reductions in peak loads as well as reductions in total energyconsumption.IPC and the EEAG falls short of its role as stated.For example , the proposed Residential Air Conditioner Cycling Pilot Program is clearly notthe resul t of a comprehensive DSM study given that residential air condi tioner cyclingtechnology and programs are more than 20 years old and several successful programs are inoperation today in California , Florida and other states. Idaho Power need not implement anexpensive, $820 000 pilot program.Addi tionally, direct load control programs can be accurately modeled using existing,reliable analytical models combined wi th readily available weather , cycling scenariosincenti ve and end-use load data for the program foot print. Therefore an expensi ve pilotprogram is not needed. Models are easily adjusted to analyze other potential direct loadcontrol programs and are scalable to fi t any size residential customer base. In summary,models can effectively and efficiently predict the success of the proposed direct loadcontrol program for a small fraction of the cost of an actual pilot program.3) The requirement that participants have only one central AC uni t and one controllingthermostat is overly restrictive and promotes diminished program resul ts because disqualifies a statistically significant number of residences wi th two central uni ts andtwo thermostats that could contribute more to load reduction than single uni t residences.Addi tionally, significantly more single uni t residences are owned be lower income families
than mul tiple uni t homes and therefore the proposed program would place a disproportionate
burden on lower income households during hot summer peaking months.
4) The $5 per month per participant incentive is overly simplistic because it fails to
recognize that residential uni ts vary in size from 2+ to 5+ tons. Therefore larger tonnage
uni ts will contribute more than twice the load reduction of smaller uni ts. A more
equi table incenti ve would be based on uni t tonnage and recognize the relati ve contribution
to load reduction of different sized uni ts. Incentives that are more reflective of
relative load reduction contribution are much more favorably received by customers and
offer enhanced opportuni ty for program success.
5) Addi tional non-complex program elements of success ful programs that could contribute to
enhanced program success are; (1) non-intrusive hardware installation (installed outsideof the residence) (2) incentives based on cycling scenarios , e.g. 100 cycling provides
higher incentive than cycling and (3) cash incentives rather than hardware incentives
(thermostats) that are proven to be more effective in ensuring program participation and
retention.
In summary, if the IPUC amends Energy Efficiency Rider , Schedule 91 to allow funds for
load control programs , the proposed residential air condi tioner cycling pilot program
remains an expensive and hastily constructed proposal. In its present form it does not
appear to be the resul t of a comprehensive study by IPC and the EEAG and the approval of
this pilot program would be an inefficient use of the Schedule 91 funds since existing
analytical models can provide a much greater range of analysis for a fraction of the
cos ts
Transaction ID: 221715.Referred by: http: / /www. puc. s tate. id. us scripts /polyform. dll/ ipucUse r Add res s: 2 4 . 11 7 . 2 2 . 5 4Us e r Ho s tname: 24. 11 7 . 22 . 54