20061108IIPA comments.pdf

LOUIS F. RACINE (1917-2005)
WILLIAM D. OLSON
W. MARCUS W. NYE
RANDALL C. BUDGE
JOHN A. BAILEY, JR.
JOHN R. GOODELL'
JOHN B. INGELSTROM
DANIEL C. GREEN"
BRENT O. ROCHE
KIRK B. HADLEY
FRED J. LEWIS
MITCHELL W. BROWN
ERIC L. OLSEN
CONRAD J. AIKEN'"
RICHARD A. HEARN, M.
DAVID E. ALEXANDERtt
LANE V. ERICKSON"
PATRICK N. GEORGE"
SCOTT J. SMITH
STEPHEN J. MUHONEN
BRENT L. WHITING
LISA R. TANNERttt
JUSTIN R. ELLIS
JOSHUA D. JOHNSON;
JONATHON S. BYINGTON
DAVE BAGLEY
CAROL TIPPI VOLYN;;
THOMAS J. BUDGE
LAW OFFICES OF
RACINE OLSON NYE BUDGE Be BAILEY
CHARTERED
BOISE OFFICE
101 SOUTH CAPITOL
BOULEVARD, SUITE 208
BOISE, IDAHO 83702TELEPHONE: [phone]
FACSIMILE: [phone]
201 EAST CENTER STREET
POST OFFICE BOX 1391
POCATELLO, IDAHO 63204-1391
TELEPHONE [phone]
FACSIMILE [phone] IDAHO FALLS OFFICE
www.racinelaw.net
477 SHOUP AVENUE
SUITE 203A
IDAHO FALLS, ID 83402TELEPHONE: [phone]
FACSIMILE: (208) 528-6 I 09
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November 7, 2006
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Jean Jewell, Secretary
Idaho Public Utilities Commission
472 W. Washington Street
Boise, Idaho 83702-5983
Dear Mrs. Jewell:
Re:Case No. IPC-O6-
Comments of Idaho Irrigation Pumpers Association
Enclosed please find an original and eight copies of the Comments of the Idaho Irrigation
Pumpers Association, Inc., for filing in the above-referenced matter.
RCB:rr
Enclosurescc: Idaho Power Company
Randall C. Budge, ISB No. 1949
RACINE, OLSON, NYE, BUDGE &
BAILEY, CHARTERED
O. Box 1391; 201 E. Center Street
Pocatello, Idaho 83204-1391
Phone: [phone]
E-mail:
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100& NOV -8 At, 9: , I
IDAHO t';LH:H.\C:
UTILITIES COivJlV\\SSIOI'i
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION
OF IDAHO POWER COMPANY
REQUESTING APPROVAL OF REVISIONS
TO ITS IRRIGATION PEAK REWARDS
PROGRAM, SCHEDULE 23
Case No. IPC-O6-
COMMENTS OF THE IDAHO IRRIGATION PUMPERS ASSOCIATION
COMES NOW the Idaho Irrigation Pumpers Association, Inc. ("Irrigators ), through counsel
and hereby submits the following Comments in support of Idaho Power Company s Application
requesting approval of changes to the Irrigation Peak Rewards Program, Schedule 23.
BACKGROUND
While the irrigation load has been relatively flat for the past 20 years, Idaho Power Company
(the Company) has experienced considerable load growth, particularly in the residential and
commercial classes. The Company s Integrated Resource Plans continue to project peak resource
deficiencies in coming years. To meet growing peak load, particularly in the summer months, the
Company has regularly bought power and has constructed new natural gas-fired peakers. The
Company has also appropriately targeted demand side resources to reduce peak demand on the
system.
The Irrigation Peak Rewards Program (formerly referred to as the Peak Clipping Program)
was implemented and became operational during the 2005 irrigation season following a successful
pilot program in 2004. According to the Company s year-end report dated December 1 2005, filed
with the Commission, the program proved to be an effective way to reduce demand at the optimal
COMMENTS OF THE IDAHO IRRIGATION PUMPERS ASSOCIATION, INe. - 1
times of the day, produced substantial and measurable impacts on peak demand and was well
received by customers. Of the 1112 eligible customers, 23 percent chose to participate in the
Program. The total load reduction associated with the Program averaged 23.8 MW from 4:00-8:00
m. over the course ofthe 2005 summer, with a maximum load reduction of 40.3 MW during the
last half of June.
The Irrigators have and continue to be an active advocate of the Peak Rewards Program. The
Irrigators ' Program objectives are simply to increase the level of participation by irrigation
customers to maximize the reduction of peak usage. This will help achieve three primary goals.
First, to reduce the irrigators' contribution to peak and thus the overall class revenue requirement.
Second, to provide a direct financial benefit for irrigators who participate in the program and method
for them to reduce pumping costs and help stay in business. Third, to reduce system costs for all
customers. These goals have been increasingly important to the Irrigators as a result of cost-of-
service studies advocated by the Company in its last two general rate cases where relative costs
assigned to the irrigation class have gone up dramatically as a result of more cost weighting being
placed upon the summer usage of all classes.
Comparing the Company s Peak Reward Program with PacifiCorp' s Irrigation Load Control
Program under Schedule 72, the Irrigators were ofthe opinion that PacifiCorp s considerably greater
level of participation and peak reduction resulted directly from greater price incentives and broader
and more flexible program terms. Consequently, in order for the Irrigators to enter into the
Stipulation settling the last Company general rate case number IPC-05-, the following
paragraph was included:
10. Idaho Power agrees that no later than November 1 2006, it will convene
a working group to review the current status of the Irrigation Peak Rewards Program
Program ), including consideration of suggested modifications to improve the
Program. Issues to be considered would include the amount of incentive payments
and the size of irrigation facilities eligible for participation in the Program. The
working group participants would include representatives of the IIP A. It is Idaho
Power s intention that any proposed modifications to the Program developed by the
working group would be presented to the Energy Efficiency Advisory Group
EEAG') and the Commission in time for such modifications to be in effect during
the 2007 irrigation season.
As a result of the Commission s approval of the Stipulation settling Case No. IPC-05-
COMMENTS OF THE IDAHO IRRIGATION PUMPERS ASSOCIATION, INe. - 2
Idaho Power conducted a workshop with the Irrigators and other interested parties to consider
proposed revisions to the Peak Rewards Program. As a result of the workshop, the Company filed
its Application to Revise the Program.
PROPOSED PROGRAM REVISIONS
The Application filed by the Company for authority to revise the Irrigation Peak Rewards
Program, Schedule 23, provides an extensive and accurate background of the workshop that was
conducted, the proposed Program modifications and the expected impact of the proposed
modifications. The workshop included several representatives ofthe Irrigators, including its counsel
and consultant, other agricultural irrigation customers, the Commission Staff and Company
representatives. The current Program along with several recommended modifications were
thoroughly researched and analyzed by the Company, openly discussed and carefully considered.
After several weeks of analysis and discussion in a collaborative process, the parties were able to
identify and agree upon two substantial changes. The first modification was to increase the demand
credits according to the following schedule:
Interruption Option Current Demand Credit per kW Proposed Demand Credit per kW
Option 1 (1 Day per Wk)
Option 2 (2 Days per Wk)
Option 3 (3 Days per Wk)
$2.
$2.
$2.
$2.
$3.
$4.
The Irrigators believe that the proposed increase in the demand credit for the two and three
day per week options will provide a greater and more fairly priced incentive, thus increasing
irrigator participation. This is expected to result in an additional reduction in the summer peak on
a cost effective basis for all customers.
The second proposed revision is a reduction in the horsepower limit for eligibility from 100
horsepower to 75 horsepower. This proposed change will make more customers eligible and is also
expected to increase participation. The Irrigators support the installation fee of $250 for those
customers with irrigation pumps between 75 and 99 cumulative horsepower in order to maintain the
cost-effectiveness ofthis program change.
Consideration was also given towards moving the current interruption period of4:00 to 8:00
m. up one hour in order to provide more daylight hours to restart equipment at the end of an
interruption period. During the end of the summer when daylight hours are shortened, darkness is
COMMENTS OF THE IDAHO IRRIGATION PUMPERS ASSOCIATION, INC. - 3
a concern to many irrigators. However, no change was made after a survey indicated that most
customers were satisfied with the current interruption period.
CONCLUSION
The Irrigators respectfully request that the Commission approve the Company s Application
and adopt the proposed revisions to the Irrigation Peak Rewards Program, Schedule 23. The
Commission should further direct the revised Program be implemented for the 2007 irrigation
season.
The Irrigators believe that the Program modifications will result in increased participation
by irrigation customers, result in additional load reduction on a cost-effective basis, and continue to
achieve a high level of satisfaction among participants. The Company should be required to file
annually a report which summarizes and assesses the results of the Program. The Irrigators believe
that the Program continues to be a work in progress. Accordingly, annual review should be required
to ensure that pricing remains on a level playing field with supply side resources and provides a
demand response that is most beneficial to both irrigation and non-irrigation customers.
Finally, the Company and particularly its participants in the workshop should be commended
for the collaborative workshop process that was conducted openly with full participation and
thorough analysis resulting in the proposed modifications by consensus.
RESPECTFULLY SUBMITTED this 7th day of November 2006.
RACINE, OLSON, NYE, BUDGE &
BAILEY, CHARTERED
RANDALL C. BUDGE Attorney for
Idaho Irrigation Pumpers Association, Inc.
COMMENTS OF THE IDAHO IRRIGATION PUMPERS ASSOCIATION, INe. - 4
CERTIFICATE OF MAILING
I HEREBY CERTIFY that on this 3rd day of November, 2006, I mailed a true and complete
copy of the foregoing document, postage prepaid, to each of the following:
Jean Jewell, Secretary (UPS/Overnight Mail)
Idaho Public Utilities Commission
472 W. Washington Street
Boise, Idaho 83702-5983
Barton L. Kline
Monica B. Moen
Maggie Brilz
Idaho Power Company
O. Box 70
Boise, Idaho 83707-0070
(J,
RANDALL C. BUDGE
COMMENTS OF THE IDAHO IRRIGATION PUMPERS ASSOCIATION, INe. - 5