20060608Reply comments.pdf

IDAHO POWER COMPANY
O. BOX 70
BOISE, IDAHO B3707
BARTON L. KLINE
Senior Attorney
An IDACORP Company . . ; i
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June 8 , 2006
Jean D. Jewell, Secretary
Idaho Public Utilities Commission
472 W. Washington Street
O. Box 83720
Boise, ID 83720-0074
Re:Case No. IPC-06-
Idaho Power Company s Reply Comments
Dear Ms. Jewell:
Please find enclosed for filing an original and seven (7) copies of Idaho
Power Company s Reply Comments regarding the above-described case.
I would appreciate it if you would return a stamped copy of this transmittal
letter in the enclosed self-addressed , stamped envelope.
Very truly yours
Barton L. Kline
BLK:jb
Enclosures
Telephone [phone] Fax [phone], E-mail BKlinefgJidahopower.com
BARTON L. KLINE ISB #152
MONICA B. MOEN ISB #5734
Idaho Power Company
O. Box 70
Boise, Idaho 83707
Telephone: [phone]
FAX Telephone: [phone]
BKline (Q? idahopower.com
MMoen (Q? idahopower.com
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Attorneys 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 REVIEW OF
IDAHO POWER COMPANY'S PHASE
ONE AMR IMPLEMENTATION STATUS
REPORT.)
CASE NO. IPC-06-
IDAHO POWER COMPANY'
REPLY COMMENTS
COMES NOW , Idaho Power Company ("Idaho Power" or "the Company
by and through its attorney of record, and in response to the comments of the
Commission Staff, hereby submits the following reply comments.
These reply comments are intended to provide additional information to
clarify several issues raised by Staff's comments dated April 25, 2006, as they relate to
the Company s 2006-2007 strategy for determining its future AMR policy.
IDAHO POWER COMPANY'S REPLY COMMENTS, Page
Sinqle-Phase Substations
On page three , paragraph three of their comments, Staff states: "TWACSCID
technology does not currently work with single-phase substations; the Company and
DCSI are currently working to rectify that issue.
The Company wishes to clarify that although the TW ACSCID technology is
not available for single phase substations at this time , the Company and DCSI are not
actively pursuing a solution to this situation. DCSI has indicated to the Company that it
is willing to work with the Company on the implementation of a single-phase station
solution with a commitment from the Company to purchase the equipment. The
Company does not believe it prudent at this time to make that level of commitment.
Single phase substations are rare and the market for this technology is small. Even if
equipment was available to enable AMR to single-phase substations , it may not be
economically feasible to do so considering the few customers served by these
substations.
Extended Memory Modules
On page four, paragraph two of their comments, Staff states: "The
Company plans to implement a new extended memory module currently in development
by DCSI within the Phase One AMR region once available to counteract this problem.
The Company plans to test the extended memory (XM) module when the
XM modules and the associated software are available from DCSI. Part of this testing
will be to determine the practicality and effectiveness of the XM module for resolving
data acquisition issues. At the present time , the Company has no plans to replace the
000 meter modules in the Phase One AMR region with the XM module.
IDAHO POWER COMPANY'S REPLY COMMENTS, Page 2
Server Capacity
On page four, paragraph two of their comments , Staff states: "It may be
prudent for the Company to acquire additional resources or expand its server capacity
to more reliably retrieve customer data within the necessary timeframe.
The constraints on retrieving data are between the TW ACSCID substation
equipment and the TWACSCID meter module. The resolution to this issue will come only
through TWACSCID system enhancements to increase data transfer. The MIRA board for
stations and XM modules for meters are two TW ACSCID enhancements that Idaho Power
will be testing. Increasing Company staffing or server resources would not have
significant impact on resolving the data retrieval issues.
Extended Memory Module
On page four, paragraph three of their comments , Staff states: "the
extended memory module provides added insurance for data collection as more
customers are converted to AMR meters.
As stated earlier, the Company plans to test the XM module when the
modules and the associated software are available from DCSI. However, it is still
unknown if the XM module will improve data collection. The difficulties in collecting data
are often a function of time. Although the XM module has extended memory and will
allow the data to be available for a longer period of time , the overall time constraints on
the system to collect data multiple times during a 24-hour day remain.
IDAHO POWER COMPANY'S REPLY COMMENTS, Page 3
On-Demand Readinqs
On page four, paragraph four of their comments , Staff states: "Due to
bandwidth limitations with the communications link and the necessity of manual
intervention , on-demand readings are not executed on a routine basis.
The Company has chosen not to execute on-demand readings on a
routine basis primarily because it is inefficient and impractical to do so. This decision
was not primarily based on bandwidth considerations. In order to retrieve the hourly
and daily readings , the Company has set up a communication and data retrieval routine
that is programmed to initiate communications four times a day between the meters
substation , and TNS server. Interrupting this routine to perform on-demand readings is
neither logical nor necessary in the normal course of business since the usage
information needed to perform several functions , such as beginning and ending meter
reads associated with customer movement, is available on a daily basis. The retrieval
of on-demand reads is performed occasionally for troubleshooting and maintenance
purposes only.
MDMS
On page five, paragraph two , Staff states: "The Company sought to
implement an MDMS system that had not yet been developed." And "Specifically,
missing hourly data for time-of-use customers was to be filled in through estimation
algorithm using the individual's load history (as opposed to using the customer class
consumption to estimate missing data, which the MDMS system was designed to do).
In January of 2004 the Company began researching Meter Data
Management Systems (MDMS) to validate , edit, and estimate (VEE) hourly data as well
IDAHO POWER COMPANY'S REPLY COMMENTS , Page 4
as aggregate this data into time-of-use or critical peak pricing components , and pass
this aggregated data to the Company s billing system. The Company could not find a
commercially available, fully developed , enterprise system. There were several
systems under development. The Itron system, although still being improved, was a
functioning software that included a customizable VEE module. Both Itron and Idaho
Power believed that customizing the estimating algorithm to utilize individuals' usage
data as a baseline for estimation was a realistic expectation. This customization
performed by Itron under contract with Idaho Power was ultimately determined to be
more difficult than expected. Idaho Power believed at the time and still believes that
using a customer s individual usage history to profile the missing hourly usage based on
the difference between the daily kWh usage (calculated from cumulative reads) and the
sum of the hourly consumptive usage, is the preferred method.
Nexus - 300 kW Usaqe Level
On page six, paragraph one of their comments , Staff states: "Nexus
accurately displays information to customers whose demand does not exceed 300 kW
although the Company has indicated that the threshold is more in the neighborhood of
500 kW (only .38% of industrial customers have a higher demand , and therefore were
unable to use this resource).
Idaho Power wishes to clarify that the Nexus Energy tools were designed
for residential customers and general service customers with up to 300 kW in average
demand. Idaho Power is currently allowing general service customers with up to 500
kW in demand access to the Nexus tools. Idaho Power has found that these tools
provide accurate data for customers up to this level of demand. Idaho Power has very
IDAHO POWER COMPANY'S REPLY COMMENTS, Page 5
few larqe qeneral service customers, approximately .38% of the class total , who are
unable to access their usage data through the Nexus Energy tools. Industrial
customers within the AMR area were not converted to meters utilizing TWACSCID meter
modules. All Idaho Power Industrial Customers have load profile metering packages
with telephone line connections. Idaho Power s Industrial Customers do not have
access to Nexus , however they can contact an Idaho Power Delivery Service
Representative (DSR) to request interval data be emailed to them concurrent with their
monthly bill. All customers can view their monthly usage information at
idahopower.com
Nexus
On page six, paragraph two of their comments , Staff states: "(Most
customers , 87% of those surveyed , prefer to receive usage analysis with their bills.
Idaho Power would like to clarify that it stated in the AMR Report: When
asked where they would prefer to get electricity usage information, 87 percent of the
customers involved in this research said they would prefer to see it their Idaho Power
bill rather than on the Idaho Power Web site. (AMR Report, page 10 , part 1) In the
customer survey conducted by Northwest Research Group, Inc in September 2005, a
sample of 533 customers was asked: 'Where would you prefer to get detailed
information about your electricity usage?" They were given two choices: "Idaho Power
bill or Idaho Power Website?" 455 (87%) replied on their Idaho Power bill , 69 (13%)
replied on Idaho Power Website , and 9 replied don t know/refused to answer.
IDAHO POWER COMPANY'S REPLY COMMENTS, Page 6
Consultinq Services
On page eight , paragraph one of their comments, Staff stated: "From
there, the Company will conduct an in-depth financial analysis with the continued
assistance of MW Consulting to evaluate the business case for further AMR
deployment."
Although Idaho Power engaged the services of MW Consulting in 2005 to
assist in our in-depth evaluation of AMR and potential future options and strategies, the
Company wishes to clarify that it currently does not have an ongoing contract with or
obligation to MW Consulting nor does MW Consulting have any commitment or
obligation to Idaho Power. The Company will continue to evaluate the costs and
benefits of employing consultants during its AMR analysis and utilize their services if
deemed of value
10.Population Densitv
On page eight, paragraph one of their comments , Staff states: "Staff would
like to see AMR deployment follow logical steps based on the Company s findings, e.
testing communication equipment in more densely populated areas as well as rural
areas that are similar to Phase One implementation.
The communication characteristics of the TW ACS(ID system are not a
function of urban or rural installation of AMR equipment. Rather, they are a function of
the substation buss section capability and are based on the volume of data being
retrieved from the meters. The communications functionality works the same in both
urban and rural environments. In the AMR Phase One Area, the Company installed the
AMR system on a bus section with approximately 6,000 customers. Idaho Power
IDAHO POWER COMPANY'S REPLY COMMENTS, Page 7
larger substations in more urban settings usually have a series of bus sections each
with approximately 6 000 customers. Given the similarity in buss section configuration
for both urban and rural substations , there is no benefit to be gained by installing and
testing TW ACSCID AMR communications equipment on urban stations instead of on those
included in the AMR Phase One Area.
Conclusion11.
Idaho Power appreciates Staff's support of the Company s Phase One
AMR Implementation Status Report ("the Report") and commits to continue working
closely with Staff as it pursues its strategy for determining its future AMR policy.
Specifically, the Company will continue testing and evaluating AMR functionality during
2006 and will work with its vendors to address the technical issues encountered during
Phase One. The Company supports Staff's recommendation that the Company file a
report by May 1 2007, detailing the advances that have been made in resolving issues
encountered during Phase One. During the first half of 2007 the Company plans to
conduct a competitive bidding process that will include new Request for Proposals to
multiple vendors. An in-depth financial analysis of AMR is planned during the second
half of 2007 using varied scenarios of cost options and benefit possibilities. The
Company believes this strategy will allow it to better understand the costs , benefits, and
customer impacts of AMR prior to final determination of its future AMR policy.
DATED at Boise. Idaho this 8th day of June
BARTON L. KLINE
Attorney for Idaho Power Company
IDAHO POWER COMPANY'S REPLY COMMENTS, Page 8
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this 8th day of June , 2006 , I served a true
and correct copy of the within and foregoing IDAHO POWER COMPANY'S REPLY
COMMENTS upon the following named parties by the method indicated below, and
addressed to the following:
Donovan E. Walker
Deputy Attorney General
Idaho Public Utilities Commission
472 W. Washington Street
O. Box 83720
Boise, Idaho 83720-0074
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CERTI FICA TE OF SERVICE, Page