20090416Application.pdf

DONOVAN E. WALKER
Corporate Counsel.
esIDA~POR~
An IDACORP Company
April 16, 2009
VIA HAND DELIVERY
Jean D. Jewell, Secretary
Idaho Public Utilities Commission
472 West Washington Street
P.O. Box 83720
Boise, Idaho 83720-0074
Re: Case No. IPC-E-09-12
IN THE MA ITER OF THE APPLICATION OF IDAHO POWER COMPANY
FOR AUTHORITY TO IMPLEMENT A COMMERCIAL AIR CONDITIONER
CYCLING PILOT PROGRAM
Dear Ms. Jewell:
Enclosed for filing please find an original and seven (7) copies of the Company's
Application in the above matter.
Finally, I would appreciate it if you would return a stamped copy of this letter for my
file in the enclosed stamped, self-addressed envelope.
yours,~IJ~
Donovan E. Walker
DEW:csb
Enclosures
P.O. Box 70 (83707)
1221 W. Idaho St.
Boise, 10 83702
DONOVAN E. WALKER (ISB No. 5921)
BARTON L. KLINE (ISB No. 1526)
Idaho Power Company
1221 West Idaho Street
P.O. Box 70
Boise, ID 83707
Tel: [phone]
Fax: [phone]
dwalker(âidahopower.com
bkline(âidahopower.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 MA ITER OF THE APPLICATION
OF IDAHO POWER COMPANY FOR
AUTHORITY TO IMPLEMENT A
COMMERCIAL AIR CONDITIONER
CYCLING PILOT PROGRAM.
)
) CASE NO. IPC-E-09-12
)
) APPLICATION
)
)
Idaho Power Company ("Idaho Powet' or the "Company"), in accordance with
Idaho Code §§ 61-502, 61-507, and 61-508 and Rules of Procedure ("RP") 52, hereby
respectfully makes Application to the Idaho Public Utilities Commission ("I PUC" or the
"Commission") for authority to implement a commercial air conditioner cycling pilot
program ("Commercial AC Cycling Program" or "the Program").
In support of this Application, Idaho Power represents as follows:
i. INTRODUCTION
1. Idaho Power is an Idaho corporation whose principal place of business is
1221 West Idaho Street, Boise, Idaho. Idaho Power is engaged in the business of
APPLICATION -1
generating, purchasing, transmitting, and distributing electrical energy and provides
retail electric service in the state of Idaho and the state of Oregon. In conducting its
business, Idaho Power operates an interconnected and integrated system. In addition
to supplying electric service to the public, Idaho Power supplies electricity at retail to
certain special contract customers and makes wholesale sales of electricity to other
electric utilities. Idaho Power is subject to the jurisdiction of this Commission, the Public
Utility Commission of Oregon, and the Federal Energy Regulatory Commission.
2. Idaho Power has received numerous inquiries and requests from its small
commercial customers about offering an AC Cycling program to the small commercial
customer group. The Company has made inquiries with several other utilities that
currently operate similar commercial AC Cycling programs, and has received widely
varying reports about the success of the programs and the quantity of energy savings
that results therefrom. Idaho Power discussed this Program with the Energy Effciency
Advisory Group ("EEAG") during its October 2, 2008, and February 19, 2009, meetings,
and the EEAG supports the Company's pursuit of the Commercial AC Cycling Pilot
Program.
3. Consequently, Idaho Power proposes to implement an air conditioner
cycling pilot program for small commercial customers similar to its current residential air
conditioner cycling program, Schedule 81. The Commercial AC Cycling Pilot Program
would run for two (2) Air Conditioning Seasons (June, July, and August), to allow
suffcient data and operational information to be obtained in order to evaluate and
consider offering a full scale commercial program.
APPLICATION - 2
II. PROGRAM DESCRIPTION
4. The Commercial AC Cycling Pilot Program is a voluntary program for
small commercial customers that wil enable Idaho Power to continue to directly address
summer peaking requirements by reducing some of the air conditioning load which is
one of the primary loads contributing to summer peak. The Program may also, through
the Programmable Controllable Thermostat ("PCT") option, help reduce overall energy
use by the participating customers and potentially decreasing Idaho Powets overall
energy costs which in turn could be potential savings to all of the Company's customers.
5. The Program wil be offered to eligible Schedule 7 customers and
Schedule 9 secondary customers with Basic Load Capacity under 200 kW in Ada and
Canyon counties. Customers wil have two options for participation in the Program: (1)
installation of a direct load control Device ("Device"), which is how the residential AC
Cycling program works and (2) installation of a PCT, which has all the functionality of a
modern programmable thermostat and, additionally, is capable of receiving a signal
enabling the Company to initiate AC Cycling.
6. The Commercial AC Cycling Pilot Program is expected to operate for two
Air Conditioning Seasons to allow suffcient data and operational information to be
obtained in order to evaluate and consider offering a full scale commercial program.
Participation in the Commercial AC Cycling Pilot Program is limited to approximately
two hundred customers. The Company may choose to solicit customers for
participation based upon their SiC code, the type and size of air conditioning equipment,
energy usage or other factors. The Company retains the sole right to ultimately select
and reject participants for the Program.
APPLICATION - 3
7. In addition to gaining operational experience and information, the goals of
the Pilot Program are to (1) evaluate the pros and cons of each type of cycling device,
(2) determine the average kilowatt ("kW") reduction of commercial AC Cycling
participants for each type of cycling device, and (3) to determine the peak load
reduction potential from participants in this pilot.
8. The Commercial Program wil work in much the same way as the
Residential AC Cycling Program. The Company or its representative wil install either a
load control Device or a PCT at the customets facility. If the customer chooses the
PCT option, the Company wil set the initial program on the thermostat upon installation,
provide training on its use, and leave documentation with the customer. The Company
wil send a signal to the Device, or the PCT, to initiate a cycling event. Cycling events
may be up to four (4) hours per day on any weekday during the Air Conditioning
Season, and may occur over a continuous four (4) hour period or may be segmented
throughout the day at the Company's discretion in order to optimize available resources.
Cycling events may occur up to fort (40) hours each month and wil not exceed a total
of one hundred twenty (120) hours per Air Conditioning Season.
9. The Company wil send either a radio/paging signal, or for those
customers in areas where the Advanced Metering Infrastructure ("AMI") installation has
taken place, a power line carrier ("PLC") signal through the AMI system.
Communications for the PCT are currently only accomplished via paging technology.
Just as in the Residential AC Cycling program, it is currently necessary for the
Company to support both a radio/paging system as well as a PLC system. Over time
the radio/paging system wil be phased out and replaced by PLC as the Company's
APPLICATION - 4
system is converted to AMI and the paging type switches fail, or need service.
Currently, the AMI capable, PLC switches are being installed wherever they can be,
following along with the AMI deployment.
10. Just as in the residential program, customers who choose the Device
option wil receive a monetary incentive of $7.00 per month for successfully participating
in the Program during the Air Conditioning Season. Customers choosing the PCT
option wil not receive a monetary incentive, but wil receive a Programmable
Controllable Thermostat as an incentive for successfully participating in the Program
during the Air Conditioning Season.
II. PROPOSED TARIFF
11. Attachment No. 1 to this Application is a copy of Idaho Powets proposed
new Tariff Schedule No. 82, which contains the tariff sheets describing the Program, its
availability, terms and conditions, and defining terms.
IV. PROGRAM COSTS
12. The Company requests that the costs of the Program be paid by use of
the Energy Effciency Rider funds collected under Schedule 91. The cost of the
Program is estimated to be approximately $325,500 for 2009 and $340,800 for 2010.
V. COST-EFFECTIVENESS AND EVALUATION
13. Idaho Power's initial cost-effective analysis of this program using the best,
although limited, data available, indicated the program was not cost-effective. This was
because the estimated installation costs for both the switch Device and the PCT are
higher for commercial customers than for residential customers, while the estimated
benefit used in the analysis was the same as that estimated in the residential program,
APPLICATION - 5
1.12 kW per customer. The program could be cost-effective if the actual average load
reduction per customer is higher than the assumed load reduction. One of the goals of
this pilot is to determine the actual load reduction from commercial installations and
identify which commercial market segment may be more likely to provide enough load
reduction to implement a cost-effective program. The Company has determined that if
an average load reduction of at least 2 kW is achieved at a 50 percent cycling rate, a
program would be cost-effective.
14. In order to estimate the load reduction potential for the program, Idaho
Power contacted several utilities that offer similar AlC cycling programs. The Company
also queried other organizations such as the Advanced Load Control Allance to
determine peak load reduction capability of the switch Device and PCT. These inquiries
indicated a broad range of load reduction capability. Because of the uncertainty of the
actual load reduction potential, Idaho Power is seeking to operate this pilot program to
obtain information necessary to evaluate load reduction attributable to the program in
Idaho Power's service territory. By operating its own pilot program, the Company can
obtain real data about its own system.
15. Idaho Power expects to collect AlC cycling data by installng data loggers
on a sample of pilot participants. The information collected wil be used to assess the
peak load reduction impacts of various commercial segments to verify the cost-
effectiveness of the pilot and the potential program. Other information used to evaluate
the pilot includes the customer preference for a switch Device or a PCT, level of comfort
during AlC cycling events, and overall customer satisfaction with the pilot.
APPLICATION - 6
Vi. MODIFIED PROCEDURE
16. Idaho Power believes that a hearing is not necessary to consider the
issues presented herein and respectfully requests that this Application be expeditiously
processed under Modified Procedure; Le., by written submissions rather than by
hearing. RP 201, et seq. If, however, the Commission determines that a technical
hearing is required, the Company stands ready to present its testimony and support the
Application in such hearing. To increase the likelihood that the Company could use the
Program to manage demand during the upcoming summer period and to maximize the
amount of information collected for further evaluation of the Program, the Company
respectfully requests that the Commission process this Application as expeditiously as
is reasonably possible.
VII. COMMUNCIATIONS AND SERVICE OF PLEADINGS
17. Communications and service of pleadings with reference to this
Application should be sent to the following:
Donovan E. Walker
Barton L. Kline
Idaho Power Company
P.O. Box 70
Boise, Idaho 83707
dwalkertâidahopower.com
bklinetâidahopower.com
Darlene Nemnich
Greg Said
Idaho Power Company
P.O. Box 70
Boise, Idaho 83707
dnemnichtâidahopower.com
gsaidtâidahopower.com
VII. REQUEST FOR RELIEF
18. Idaho Power respectfully requests that the Commission issue an Order:
(1) authorizing that this matter may be processed by Modified Procedure, (2) approving
the new Commercial AC Cycling Pilot Program, Tariff Schedule No. 82, in its entirety,
APPLICATION -7
without material change or condition, and (3) authorizing the Company to recover the
Program costs/expenses from the Energy Effciency Rider funds.
DATED at Boise, Idaho, this 16th day of April 2009.
ONOVAN E. WALKER
Attorney for Idaho Power Company
APPLICATION - 8
BEFORE THE
IDAHO PUBLIC UTiliTIES COMMISSION
CASE NO. IPC-E-09-12
IDAHO POWER COMPANY
TARIFF
ATTACHMENT NO.1
Idaho Power Company
I.P.U.C. No. 29, Tariff No. 101 Original Sheet No. 82-1
SCHEDULE 82
COMMERCIAL AIR CONDITIONER
CYCLING PILOT PROGRAM
(OPTIONAL)
PURPOSE
The Commercial Air Conditioner Cycling Pilot Program is an optional, supplemental
service that permits participating Schedule 7 and Schedule 9 secondary customers with Basic
Load Capacity under 200 kW an opportunity to allow the Company to cycle their central air
conditioners with the use of either a direct load control device ("Device") or a Programmable
Controllable Thermostat ("PCT") installed at their facilty. The operation of this Program wil act
as a demand-side resource for the Company to help defer construction of additional generation
facilities. Customers who choose a direct load control Device wil receive a monthly monetary
incentive for successfully participating in the Program during the Air Conditioning Season.
Customers choosing the PCT option will receive a programmable Thermostat as an incentive for
successfully participating in the Program for a complete Air Conditioning Season.
DEFINITIONS
AC Cycling is the effect of the Company sending a signal to the PCT installed in the
Customets facility and instructing it to cycle the Central Air Conditioning compressor for a
specified length of time on a percentage basis, to cycle the Central Air Conditioning compressor
until a specified temperature change is attained, or to change the temperature set point on the
thermostat for a specified length of time. In the case of the direct load control Device, the AC
cycling is the effect of the Company sending a signal to a Device installed at the Customer's
facilty and instructing it to cycle the Central Air Conditioning compressor for a specified length
of time on a percentage basis.
Agreement is the Uniform Commercial Thermostat Air Conditioner Cycling Service
Agreement.
Air Conditioning Season is the three-month period that commences on June 1 and
continues through August 31 of each calendar year.
Central Air Conditioning is a cooling system that is controlled by one or more centrally
located thermostats that control one or more refrigerated air-cooling units located outside the
Customer's building.
Cycling Event is a period during which the Company sends a signal either to the Device
installed at the Customets facility, which instructs the Device to begin AC Cycling or to the PCT
installed in the Customer's facility which instructs the thermostat to begin AC Cycling.
Device is a direct load control device installed at a Customer's facilty that enables the
Company to initiate AC Cycling.
IDAHO
Issued - April 16, 2009
Effective - June 1, 2009
Issued by IDAHO POWER COMPANY
John R. Gale, Vice President, Regulatory Affairs
1221 West Idaho Street, Boise, Idaho
Idaho Power Company
I.P.U.C. No. 29, Tariff No. 101 Original Sheet No. 82-2
SCHEDULE 82
COMMERCIAL AIR CONDITIONER
CYCLING PILOT PROGRAM
(OPTIONAL)
DEFINITIONS (Continued)
Notification refers to the Customer's indication of intent to initiate or terminate
participation in the Program, and to elect the use of either the Device or the PCT option, by
either contacting the Company's Customer Service Center, or providing written notice.
Program Operation Area describes the area in which the Program wil be offered to
Customers and is comprised of Ada and Canyon counties in the State of Idaho.
Programmable Controllable Thermostat ("PCT") is an intellgent Programmable
Controllable Thermostat capable of receiving a signal enabling the Company to initiate AC
Cycling.
AVAILABILITY
Service under this schedule is available on an optional basis to Customers taking
service under Schedule 7 or Schedule 9 secondary with Basic Load Capacity under 200 kW
who have Central Air Conditioning located at their facilities and operate within the Program
Operation Area. Each eligible Customer who chooses to take service under this optional
schedule is required to provide Notification, indicating their election of either the Device option
or the PCT option. In the case of electing the PCT option, the Customer is required to enter into
the Agreement with the Company. These elections must be made prior to being served under
this schedule.
Service under this schedule is limited to approximately two hundred Customers. The
Program wil operate for two Air Conditioning Seasons and wil terminate on October 31, 2010.
However, if it is determined that enough data has been gathered to accomplish Pilot Program
goals in the first summer season, the Program may terminate on October 31, 2009. The
Company may choose to solicit Customers for participation based on Customets SiC code, the
type and size of air conditioning equipment, energy usage, or other factors. Customers' Central
Air Conditioning equipment must be fully functional and comply with the National Electric Code
(NEC) standards. The Company retains the sole right to select and reject the participants under
this schedule. Customers who are renting or leasing their business facilty must provide to the
Company or their contractor, written proof of the express permission of the owner of the Central
Air Conditioning system prior to acceptance into the program.
TERMS AND CONDITIONS
Upon acceptance into the Program, Customers will be subject to the following terms and
conditions
1. Each eligible Customer who chooses to take service under this optional schedule
is thereby giving the Company or its representative permission, on reasonable notice, to enter
the Customer's facility or property to install a Device or a PCT and, in certain cases, either a
IDAHO
Issued - April 16, 2009
Effective - June 1, 2009
Issued by IDAHO POWER COMPANY
John R. Gale, Vice President, Regulatory Affairs
1221 West Idaho Street, Boise, Idaho
Idaho Power Company
I.P.U.C. No. 29, Tariff No. 101 Original Sheet No. 82-3
SCHEDULE 82
COMMERCIAL AIR CONDITIONER
CYCLING PILOT PROGRAM
(OPTIONAL)
TERMS AND CONDITIONS (Continued)
mass memory meter or an end-use meter and to allow Idaho Power or its representative, with
prior notice to the Customer, reasonable access to the Device, or PCT, or other Program-
related equipment following its installation.
2. Customers added to the Program during the Air Conditioning Season and
choosing the Device option must be effectively participating in the Program prior to the 20th day
of the month in order to receive an incentive payment for that initial month.
4. A Customer may discontinue participation in the Program without penalty by
providing Notification to the Company. However, if a Customer chooses to participate in the
PCT option, and notifies the Company that he/she wishes to terminate participation in the
Program prior to completing one full Air Conditioning Season, the Customer wil have the option
of either returning the PCT in working condition to the Company within ten days from the date of
their Notification or be charged $175 for the PCT, which sum wil be included on the Customer's
Idaho Power BilL.
5. If there is evidence of alteration, tampering, or otherwise interfering with the
Company's ability to initiate a Cycling Event, the Customer's participation in the Program wil be
terminated and the Customer wil be required to reimburse the Company for the cost of
replacement or repair of the Device or PCT or other Program equipment and the Company wil
reverse any amounts credited to the Customer's bils during the past twelve months as a result
of the Customer's participation in the Program.
PROGRAM DESCRIPTION
1. At the Company's expense, either the Company or its representative wil install a
Device at the Customer's facility, or the Company or its representative wil uninstall the
Customer's existing thermostat and install a PCT in the Customets facility at the Company's
expense. The Company or its representative wil set the initial program on the PCT.
2. For Customers choosing the Device option, a financial incentive of $7.00 per
month for each of the three months of the Air Conditioning Season wil be paid to each
Customer who successfully participates in the Program. This incentive wil be paid in the form
of a credit on the Customets monthly bil for each month that the Customer successfully
participates in the Program, beginning with the July bil and ending with the September bilL.
Incentive payments are limited to one controlled Central Air Conditioning unit per metered
service point. Customers who have more than one Central Air Conditioning unit at a metered
service point may participate in the Program. A Device must be installed at each Central Air
Conditioning unit. However, no additional incentive wil be paid.
Customers choosing the PCT option wil not receive a direct financial incentive.
Instead, Customers wil receive and own the Programmable Controlled Thermostat installed
though this program at their facilty
IDAHO
Issued - April 16, 2009
Effective - June 1, 2009
Issued by IDAHO POWER COMPANY
John R. Gale, Vice President, Regulatory Affairs
1221 West Idaho Street, Boise, Idaho
Idaho Power Company
I.P.U.C. No. 29, Tariff No. 101 Original Sheet No. 82-4
SCHEDULE 82
COMMERCIAL AIR CONDITIONER
CYCLING PILOT PROGRAM
(OPTIONAL)
PROGRAM DESCRIPTION (Continued)
3. The Company wil send a signal to the Device to initiate a Cycling Event. A
Cycling Event may be up to four hours per day on any weekday during the Air Conditioning
Season. A Cycling Event may occur over a continuous 4-hour period or may be segmented
throughout the day at the Company's discretion in order to optimize available resources.
Cycling Events may occur up to 40 hours each month and wil not exceed a total of 120 hours
per Air Conditioning Season. Mass memory meters or end-use meters may be installed on
some Customers' facilities or Central Air Conditioning units for program evaluation purposes.
The facilities or Central Air Conditioning units selected for installation of the meter shall be at the
Company's sole discretion.
SPECIAL CONDITIONS
The Company is not responsible for any consequential, incidental, punitive, exemplary or
indirect damage to the participating Customer or third parties that results from AC Cycling, from
the Customer's participation in the Program, or of Customets efforts to reduce peak energy use
while participating in the Program.
The Company makes no warranty of merchantability or fitness for a particular purpose
with respect to the Device or PCT and any and all implied warranties are disclaimed.
The Company shall have the right to select the AC Cycling schedule and the percentage
of Customers' Central Air Conditioning systems to cycle at anyone time, up to 100%, at its sole
discretion.
The provisions of this schedule do not apply for any time period that the Company
interrupts the Customer's load for a system emergency or any other time that a Customer's
service is interrupted by events outside the control of the Company. The provisions of this
schedule wil not affect the calculation or rate of the regular Service or Energy Charges
associated with a Customer's standard service schedule.
IDAHO
Issued - April 16, 2009
Effective - June 1, 2009
Issued by IDAHO POWER COMPANY
John R. Gale, Vice President, Regulatory Affairs
1221 West Idaho Street, Boise, Idaho
Idaho Power Company
I.P.U.C. No. 29, Tariff No. 101 Original Sheet No. 82-5
SCHEDULE 82
COMMERCIAL AIR CONDITIONER CYCLING
PILOT PROGRAM
(OPTIONAL)
Uniform Commercial Thermostat Air Conditioner Cycling Service Agreement
ACCOUNT NO.
This Agreement made this day of 20_, between
, hereinafter calledCustomer, with premises at ,
Idaho, hereinafter called Premises, and IDAHO POWER COMPANY, a corporation with its
principal offce located at 1221 West Idaho Street, Boise, Idaho, hereinafter called Company:
NOW, THEREFORE, The Parties agree as follows:
1. With prior reasonable notice from the Company, the Customer shall permit the
Company or its representative to enter the Premises to remove the Customer's existing
thermostat and replace that thermostat by installng a Programmable Controllable Thermostat
selected by the Company ("PCr').
2. During the Term of this Agreement and with prior reasonable notice, the
Customer agrees to permit the Company or its representative reasonable access to the
Premises and the PCT for reasons including, but not limited to, collecting data recorded by the
PCT and checking the working condition of the PCT.
3. The Customer understands and acknowledges that by participating in the
Program, the Company shall, at its sole discretion, have the abilty to override the Customer's
settings on the PCT and instruct the PCT to interrupt service and begin cycling the Customer's
central air conditioner compressor (the "Cycling Event").
4. For the Customets satisfactory participation in the Program for at least one
complete Air Conditioning Season (June, July, and August), the Company agrees that the PCT
shall then become the property of Customer.
5. If the Customer terminates this Agreement prior to the Customer satisfactorily
participating in the Program for a minimum of one complete Air Conditioning Season, the
Customer agrees to either (1) return the PCT to the Company in working order within ten days
from the time the Company receives written notice of the Customer's termination of the
Agreement or (2) pay the Company the sum of $175.00, which sum wil be included on the
Customer's Idaho Power BilL.
6. The Company's Tariff Schedule 82, any revisions to that schedule, and/or any
successor schedule, is to be considered part of this Agreement.
7. This Agreement and the rates, terms and conditions of service set forth or
incorporated herein and the respective rights and obligations of the Parties hereunder shall be
subject to valid laws and to the regulatory authority and orders, rules and regulations of the
Idaho Public Utilities Commission and such other administrative bodies having jurisdiction.
IDAHO
Issued - April 16, 2009
Effective - June 1, 2009
Issued by IDAHO POWER COMPANY
John R. Gale, Vice President, Regulatory Affairs
1221 West Idaho Street, Boise, Idaho
Idaho Power Company
I.P.U.C. No. 29, Tariff No. 101 Original Sheet No. 82-6
SCHEDULE 82
COMMERCIAL AIR CONDITIONER CYCLING
PILOT PROGRAM
(OPTIONAL)
Uniform Commercial Thermostat Air Conditioner Cycling Service Agreement
(Continued)
8. Nothing herein shall be construed as limiting the Idaho Public Utilities
Commission from changing any terms, rates, charges, classification of service or any rules,
regulations or conditions relating to service under this Agreement or construed as affecting the
right of the Company or the Customer to unilaterally make application to the Commission for
any such change.
9. In any action at law or equity under this Agreement and upon which judgment
rendered, the prevailing Party, as part of such judgment shall be entitled to recover all costs,
including reasonable attorneys fees, incurred on account of such action.
(APPROPRIATE SIGNATURES)
IDAHO
Issued - April 16, 2009
Effective - June 1, 2009
Issued by IDAHO POWER COMPANY
John R. Gale, Vice President, Regulatory Affairs
1221 West Idaho Street, Boise, Idaho