20040317Reply Comments.pdf

MONICA MOEN ISB #5734
Idaho Power Company
P. O. Box 70
Boise, Idaho 83707
Telephone No. [phone]
FAX Telephone No. [phone]
f~Cf~iVED
'-"
! t- '"
~ ;., ::" ,
f7i
...-.
':""f ,-11" J"
\ -. ""
"0"
,. 0'
, "
i;iL;id:.~; CGI'li'USSION
Attorney for Idaho Power Company
Street Address for Express Mail
1221 West Idaho Street
Boise, Idaho 83702
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE
APPLICATION OF IDAHO POWER
COMPANY FOR AUTHORITY TO
IMPLEMENT AN IRRIGATION PEAK
CLIPPING PILOT PROGRAM
REPLY OF IDAHO POWER
COMPANY TO THE
COMMENTS OF THE
COMMISSION STAFF AND
THE IDAHO IRRIGATION
PUMPERS ASSOCIATION
CASE NO. IPC-04-
COMES NOW Idaho Power Company ("Idaho Power" or "the Company ) and
pursuant to Idaho Public Utilities Commission ("IPUC" or the "Commission ) Order No. 29430
issued on February 18, 2004, hereby submits the following reply comments to the comments
offered in this matter by the Commission Staff ("Staff') on March 10, 2004 and by the Idaho
Irrigation Pumpers Association on February 24, 2004.
The Company appreciates the general support of the Company s proposed
Irrigation Peak Clipping Pilot Program (the "Program ) and Tariff Schedule 23 by the Staff and
REPLY COMMENTS OF IDAHO POWER COMPANY - 1
the Idaho Irrigation Pumpers Association.The following reply comments respond to the
comments offered by the Staff concerning the proposed Program and Schedule 23.
Customer versus Metered Service Point:On page 4 of the Staff'
comments, the Staff correctly notes in footnote 1 that Idaho Power intends to accept 200 metered
service points into the Program instead of 200 customers as stated in the Company s Application
and proposed tariff.Both the Application and the tariff should be revised to note this
clarification. Should the Commission determine in favor of the Application and Schedule 23, the
Company recommends it be directed to submit tariff sheets for Schedule 23 that are corrected in
conformance with Exhibit 2 attached hereto.
Pro2ram A vailabilitv: In its comments, the Staff inquires whether a pilot
program is necessary to achieve the goals set forth by the Company for this Program. Through
deployment of other load control pilot programs, it is the Company s experience that it is prudent
to conduct pilot programs before generally offering programs of this nature to all of the
Company s qualified customers.
Pilot programs allow the Company to gain experience in operating and managing
a new program and testing new equipment and technology that may be used in a fully developed
program. A pilot program also allows the Company to test the assumptions that it used in its
analysis for program design.Furthermore, through a pilot program, the Company has an
opportunity to install the equipment and systems used to operate these programs incrementally.
The knowledge and experience gained by the Company in a pilot program enables the Company
to offer the broader range of customers a more established and better-managed program. Using
this method of evaluating and testing a new program generally translates into higher customer
REPLY COMMENTS OF IDAHO POWER COMPANY - 2
satisfaction. Greater customer satisfaction, as a rule, results in enhanced customer participation
that, in turn, results in increased peak load reduction , the goal of this Program.
Staff states that its position concerning general availability of the Program
throughout the Company s service area is consistent with the recommendation concerning the
Program made by the Energy Efficiency Advisory Group ("EEAG"). Specifically, Staff notes
that at its January 14, 2004 meeting, the EEAG recommended that Idaho Power launch the
Program as a full program rather than a pilot or add more service points to increase the size of
the pilot program. While Staff is correct in its representation, it should be noted that there was
not unanimous agreement among the EEAG members regarding the scope of the initial Program.
Some EEAG members supported offering the program as a pilot only while others supported
initiating a full program during the upcoming irrigation season. Rather than launching a full
program, the Company decided to increase the size of the pilot program, as recommended by
some of the EEAG members, by increasing the number of participants from the 100 metered
service points originally proposed to 200 metered service points and to offer the pilot program in
four areas within the Company s service territory rather than in a single test area.
The Company concurs with Staff's general observation that it is likely too late to
make the proposed Program available to all the Company s customers who may wish
participate in the Program during the 2004 irrigation season.Offering the Program to a
maximum of 200 metered serVIce points in four different areas of the Company s serVIce
territory is the reasonable number the Company believes can practically be served in time for the
2004 irrigation season. In addition , distributing the number of participants in the pilot program
to 50 metered service points in four areas of the service territory will permit the Company to
REPLY COMMENTS OF IDAHO POWER COMPANY - 3
better assess volunteerism. Therefore, Idaho Power respectfully requests that the participation
level of the Program during 2004 be limited to 200 metered service points.
Number of Hours of Interruption: In its comments Staff also notes that
the EEAG recommended the Company consider expanding the hours of interruption or use the
pilot to test whether to expand the hours.Again, the EEAG was not unanimous in its
recommendation concerning the number of hours of interruption favored for the pilot program.
EEAG members representing the irrigation customers and Idaho Power s agricultural irrigation
expert maintained that four hours per week was a reasonable number of hours to interrupt
irrigation load without adversely affecting crop production or encouraging irrigators to change
the size or design of their irrigation systems to participate in this Program. The Idaho Irrigation
Pumpers Association generally supported the Program as set out in the Company s Application.
See Idaho Irrigation Pumpers Association Comments dated February 24, 2004.
The Company intends to use the results of the pilot program to assess the efficacy
of using timers on irrigation pumps to reduce summer peak; to determine customer participation
volunteerism, satisfaction and retention; and to monitor any unintended consequences from the
Program. In addition, offering the Program in different areas of the Company s service territory
would allow the Company to weigh the success of the Program across different geographic and
climatic regions of the Company s service territory.
The Program participants will be surveyed to determine their satisfaction with the
Program and to judge whether increased hours of load reduction would be practically possible.
The Company also intends to survey some non-participating irrigation customers to determine if
the number of hours of load reduction in the pilot program was a factor in their decision not to
participate in the Program. The Company respectfully requests that it be permitted to rely on the
REPLY COMMENTS OF IDAHO POWER COMPANY - 4
results of the Program and the proposed surveys to determine the suitable number of hours of
interruption for any subsequent Program years.
Number of Interruptions Per Week Staff recommends that irrigation
customers participating in the Program be given the option of multiple load interruptions within a
week. Based on the recommendations of the Company s agriculture expert and its irrigation
customers, the Company has proposed one four-hour load interruption per week per metered
service point.
The Company believes that this level of interruption will allow most irrigators an
opportunity to participate in the Program without reducing crop production or encouraging the
modification of their irrigation systems. Too many interruptions may encourage customers to
attempt to reduce production to take advantage of the incentives. It is not the intention of the
Company to affect externalities such as economic activities in the rural areas, crop production or
local employment with this Program. Further, if irrigation customers decide to resize their
irrigation equipment to participate in this Program, this would place an increased demand on the
Company s system at all other times. For these reasons, the Company strongly urges the
Commission to approve the Program as filed.
However, should the Commission determine that the Company should increase
the amount of load interruptions per metered service point per week beyond the one
recommended by the Company, the Company recommends offering Program participants the
following three options:
(a) Four hours one day per week at $1.75 per kW of Billing Demand;
(b) Four hours two days per week at $1.88 per kW of Billing Demand; or
(c) Four hours three days per week at $2.00 per kW of Billing Demand.
REPLY COMMENTS OF IDAHO POWER COMPANY - 5
Although the Company recommends limiting the pilot program to one
interruption per week, it believes the three options identified and the incentive level associated
with each of the options are reasonable and should meet the Company s objective of not
encouraging reduced consumption or redesigned systems.
Pro2ram Year 2005 A vailabilitv Staff recommends that the Program be
made available to all customers for the 2005 irrigation season. The Company believes that the
decision to develop any direct load control program should be made through the Integrated
Resource Plan ("IRP") process. If the analysis associated with the 2004 IRP shows that this
Program is a cost effective resource and if the results of the 2004 pilot program indicate that
irrigation peak clipping is a viable demand response program, the Company suggests the
appropriate process for determining the program scope beyond the 2004 irrigation year is
through the EEAG.The EEAG is the appropriate forum for formulating, evaluating and
implementing energy efficiency and demand reduction programs.
Amount of Load Reduction: Staff indicates in its comments that the
load reduction from the Program would be 19 kW per metered service point and 27 MW of load
reduction from 1,400 metered service points. While the Company does not understand the
precise method used by Staff to calculate this amount of load reduction or know the source of
this information, the Company wishes to clarify its calculations and assumptions of the load
reduction estimates presented to the EEAG.
The Company expects approximately 109 kW of load reduction per metered
service point in a fully implemented Irrigation Peak Clipping Program. This calculation is based
on the assumptions that the average metered service point would be approximately 150
REPLY COMMENTS OF IDAHO POWER COMPANY - 6
horsepower in size and that the Program would likely attain a participation level of 10% of the
Company s eligible customers.
Based upon those assumptions, about 1,400 metered service points would be
expected to participate in the Program. At this participation level, the Company could attain 168
MW of load reduction over five weekdays or 33.6 MW load reduction per weekday. With a 20%
uncertainty discount, this would equate to a 27 MW load reduction per weekday. Since only
one-fifth of the 1,400 metered service points, or 280 metered service points, would be turned off
per weekday, a reduction of 96 kW per metered service point per day would be expected. When
this number is adjusted for losses to represent the amount of load reduction at the generation
level, the Company would expect an approximate 109 kW load reduction per metered service
point.
Reportin2 Requirements Staff recommends that the Company file a
report on this Program no later than December 1 , 2004. This reporting deadline is reasonable
and would afford the Company an opportunity to make prudent decisions concerning extension
of the Program beyond the 2004 irrigation season.
Respectfully submitted this /1d-day of March 2004.
(fJ.
MONICA B. MOEN
Attorney for Idaho Power Company
REPLY COMMENTS OF IDAHO POWER COMPANY - 7
CERTIFICA TE OF MAILING
I HEREBY CERTIFY that on the ('lu day of March 2004 , I served a true and correct
copy of the within and foregoing REPLY COMMENTS OF IDAHO POWER COMPANY upon
the following named parties by the method indicated below, and addressed to the following:
COMMISSION STAFF
John R. Hammond, Jr.
Deputy Attorney General
Idaho Public Utilities Commission
O. Box 83720
Boise, ID 83720-0074
Hand Delivered
u.s. Mail
Overnight Mail
FAX
IDAHO IRRIGATION PUMPERS
ASSOCIA TION, INC.
Randall C. Budge
Racine, Olson, Nye, Budge & Bailey
O. Box 1391
Pocatello, ID 83204-1391
--1L
Hand Delivered
u.S. Mail
Overnight Mail
FAX
MONICA B. MOEN
CERTIFICATE OF SERVICE
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
CASE NO. IPC-O4-
IDAHO POWER COMPANY
EXHIBIT 2
IDAHO POWER COMPANY
I.P.C. NO. 26, TARIFF NO. 101 ORIGINAL SHEET NO 23-
SCHEDULE 23
IRRIGATION PEAK CLIPPING
PILOT PROGRAM
(Optional)
PURPOSE
The Irrigation Peak Clipping Pilot Program ("the Program ) is intended to test the viability of
decreasing the Company s system summer peak with the use of electronic timer switches ("Timer ) to
turn off power to selected irrigation equipment during peak weekday hours in the summer months. The
Program is an optional, supplemental service that permits participating irrigation Customers to allow the
Company to turn off the power to specific irrigation equipment on a regular basis with the use of a
Timer. In exchange for allowing the Company to turn off power to specified irrigation equipment,
participating Customers will receive a monthly monetary incentive paid on the basis of the kW of load
reduction, as measured by the Customer's Billing Demand, at the Customer's metered service point
("Metered Service Point"). The Program will be piloted during the 2004 irrigation season and will expire
on October 1, 2004, unless extended by the Company.
AVAILABILITY
Service under this schedule is available on an optional basis to Customers with a Metered
Service Point or Points receiving service under Schedule 24 where the Metered Service Point serves a
water pumping or water delivery system used to irrigate agricultural crops or pasturage. If a Metered
Service Point provides electricity to more than one irrigation pump, each pump will be scheduled for
service interruption on the same weekday cycle. Metered Service Points eligible for this Program must
provide electric service to irrigation pumps with at least 150 cumulative horsepower. The Company will
make this optional service available to up to 50 Customors Metered Service Points in each of four areas I
of the Company s service territory. Customers will be selected from the Kuna/Melba/Nampa area, the
Mountain Home/Bruneau/Grand View area, the Rupert/Paul area, and the American Falls area
Idaho Power's service territory. A total of not more than 200 customers Metered Service Points will be
selected for this Program.
The Company may choose to accept Metered Service Points for participation based
demand, location, size of pump(s) or other factors aimed at creating a diverse participation in the
Program. The Company may also choose to solicit participants to fill any vacancies caused by attrition
in order to maintain the participation objectives. The Company retains the sole right to select and reject
the participants under this schedule.
Each eligible Customer who chooses to take service under this optional schedule is required to
enter into a Uniform Irrigation Peak Clipping Service Application/Agreement ("Agreement") with the
Company prior to being served under this schedule. The Agreement will grant the Company or its
representative permission, on reasonable notice, to enter the Customer's property to install a Timer or
Timers on the electrical panel servicing the irrigation equipment associated with the Metered Service
Points that are enrolled on this Program and to allow the Company or its representative reasonable
access to the Timer following its installation.
IDAHO
Issued - February 5, 2004
Effective - March 6, 2004
Issued by IDAHO POWER COMPANY
John R. Gale, Vice President, Regulatory Affairs
1221 West Idaho Street, Boise, Idaho