20070405Comments.pdf

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DONOVAN E. WALKER
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 5921
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Street Address for Express Mail:
472 W. WASHINGTON
BOISE, ID 83702-5983
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION OF
IDAHO POWER COMPANY FOR AUTHORITY)
TO IMPLEMENT TIME-VARIANT ENERGYPRICING PROGRAMS
CASE NO. IPC-O7-
COMMENTS OF THE
COMMISSION STAFF
The Staff of the Idaho Public Utilities Commission, by and through its Attorney of record
Donovan E. Walker, Deputy Attorney General, in response to Order No. 30275, the Notice of
Application and Notice of Modified Procedure issued on March 15 2007, respectfully submits the
following comments.
THE COMPANY'S APPLICATION
On February 28, 2007, Idaho Power Company filed an Application seeking authority to
implement two time-variant energy pricing programs for customers in the Emmett and Letha
Idaho vicinities (Emmett Valley). The two time-variant pricing programs, Energy Watch and
Time-of-Day, were previously approved as pilot programs in March 2005 , and authorized to
continue through April 1 , 2007. See Order No. 30037, Case No. IPC-06-05. The two pilot
programs were available to customers in the Emmett Valley who had AMR metering installed.
STAFF COMMENTS APRIL 5, 2007
Under both pilot programs, the pricing for energy consumption during the months of June, July,
and August included a time-variant component. For all other months, the pricing was identical to
that for standard residential service under Schedule 1. The Company wishes to continue offering
these programs to customers in the Emmett Valley, allowing continued evaluation and refinement
of the programs and internal systems required to run them.
The Company states it filed reports with the Commission detailing the results of the pilot
programs' operation. A report for the first year of operation was filed on March 29 2006, and a
report for the second year of operation was filed on February 28 2007. The Company requests
that the Commission take administrative notice of those filings in this proceeding. The Company
states that the analyses from those reports shows that: Overall, the participants in the pilots were
satisfied with the programs; on average, customers benefited (saved money) by participating in the
programs; on average, the participants reduced household energy demand; and customer retention
in the programs was relatively high. The Company states that based upon the results of the pilot
programs, including the high level of customer satisfaction, that it is proposing to maintain the
same program design and pricing going forward as that implemented for the pilots during the
summer of2006.
Under the Energy Watch Program, Schedule 4, customers would pay a substantially
increased flat rate for energy consumption during a designated Energy Watch Period. Energy
Watch Periods will be determined by the Company. Program participants will be notified of the
declared Energy Watch Period by 4:00 p.m. the day ahead by telephone and, where available, by e-
mail. Energy Watch Periods can occur on any weekday from June 15 through August 15, and will
be for the hours of 5 :00 p.m. to 9:00 p.m. The Company proposes that the Energy Watch Periods
will occur on no more than 10 days from June 15 to August 15 , for a total of 40 hours. The base
energy rate for the Energy Watch Program would be equal to the first block energy charge under
Schedule 1 , currently 5.425l~ per kWh. During Energy Watch Periods the proposed base energy
rate is 20~ per kWh. The over-300 kWh pricing block will be eliminated. Customers participating
in the Energy Watch Pilot Program would continue to pay the monthly service charge of $4.00.
Under the Time-Of-Day Program, Schedule 5 , customers would be given the opportunity to
reduce their electric bills by shifting their summer usage, based upon three different price
categories , from "on-peak" periods, when the cost to provide energy is highest, to the "off-peak"
periods, when the cost to provide energy is the lowest. During the non-summer season, the pricing
STAFF COMMENTS APRIL 5 , 2007
would be the same as that under Schedule 1 , currently 5.425l~ per kWh. The three time-of-day
periods for the summer season are defined and priced as follows:
Time-or-Day
Period
On-Peak
Mid-Peak
Definition Energy Rate
Off-Peak
1 :00 p.m. to 9:00 p., Monday through Friday
7:00 a.m. to 1 :00 p., Monday through Friday
9:00 p.m. to 7:00 a.m. on all days and all hours
Saturday, Sunday, and the Fourth of July
3279~ per kWh
l060~ per kWh
5l45~ per kWh
The summer and non-summer seasons are defined the same as under Schedule 1 , with the summer
season beginning June 1 and ending August 31. Customers participating in the Time-of-Day Pilot
Program will continue to pay the monthly service charge of$4.00.
STAFF ANALYSIS
Staff has reviewed the Company s filing and the evaluation reports of the second year of
operation for both pilot programs. Staff agrees with the Company s assessment that additional
questions and issues remain, particularly in the integration bfthe AMR meter data into the
Company s standard billing procedures and operations. Staff recommends that continued
operation of the pilot programs would be beneficial. The Company s previous applications for
operation of these pilot programs were for a fixed time period, each basically covering a single
summer. This application does not identify an end date. Staff believes that the operational issues
identified during the first two years of pilot programs must be resolved prior to any significant
expansion of these programs. Therefore, Staff believes it is reasonable to continue the programs
on a pilot basis for an indefinite period until these issues are resolved. However, Staff also
recommends the Company be directed to file an annual report on the progress made and
information gained from the previous year s operation ofthe pilots. This report should be filed
before the end of January of the following year. Staff and the Company have discussed evaluation
plans for the operation of the programs in 2007, and would continue these discussions for any
future years.
STAFF COMMENTS APRIL 5 , 2007
STAFF RECOMMENDATION
Staff recommends the Commission approve Idaho Power s application to continue the two
time variant pricing pilot programs, and that the Company be directed to file annual progress
reports as stated above.
Respectfully submitted this ~..,t... day of April 2007.
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Deputy Attorney General
Technical Staff:Wayne Hart
Dave Schunke
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STAFF COMMENTS APRIL 5, 2007
CERTIFICATE OF SERVICE
HEREBY CERTIFY THAT I HAVE THIS 5TH DAY OF APRIL 2007
SERVED THE FOREGOING COMMENTS OF THE COMMISSION STAFF, IN
CASE NO. IPC-07-, BY MAILING A COpy THEREOF, POSTAGE PREPAID, TO
THE FOLLOWING:
BARTON L KLINE
SENIOR ATTORNEY
IDAHO POWER COMPANY
PO BOX 70
BOISE ID 83707-0070
RIC GALE
VP - REGULATORY AFFAIRS
IDAHO POWER COMPANY
PO BOX 70
BOISE ID 83707-0070
SECRETAR
CERTIFICATE OF SERVICE