20090612Reply Comments.pdf

DONOVAN E. WALKER
Corporate Counsel
RECEIVED
eslDA~POR~
An IDACORP Company
June 12,2009
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
COMMERCIAL AIR CONDITIONER CYCLING PILOT PROGRAM
Dear Ms. Jewell:
Enclosed for filing please find an original and seven (7) copies of the Idaho Power
Company's Reply Comments in the above matter.
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, Idaho 83707
Telephone: [phone]
Facsimile: 208-388-6936
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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 MAnER OF THE APPLICATION
OF IDAHO POWER COMPANY FOR
AUTORHITY TO IMPLEMENT A
COMMERCIAL AIR CONDITIONER
CYCLING PILOT PROGRAM.
)
) CASE NO. IPC-E-09-12
)
) IDAHO POWER COMPANY'S
) REPLY COMMENTS
)
Idaho Power Company ("Idaho Powet' or "Company") respectfully submits the
following Reply Comments in response to the Comments filed by the Commission Staff
("Staff') on June 9, 2009.
The Company proposed this pilot program because of the urging and support it
received from its Energy Effciency Advisory Group ("EEAG"), of which Staff is a
participant. Additionally, there are no demand response programs currently available
for small commercial customers (served under Schedule 7 and Schedule 9 Secondary,
under 200 kilowatt ("kW") in demand), and the Company has had customer requests for
an air conditioner ("AlC") cycling program from this customer group.
IDAHO POWER COMPANY'S REPLY COMMENTS - 1
As stated in both the Company's Application and in Staffs Comments, the
program is not cost-effective using the estimated energy savings of 1.12 kW, which is
the average residential load reduction in the residential AlC Cool Credit program. Staff
points out that the Company has previously estimated for the EEAG that the potential
energy savings from a small commercial AlC cycling program would likely be in a range
between .88 kW and 1.54 kW per unit. The Company estimates that an average load
reduction of at least 2 kW, at a 50 percent cycling rate, is needed for the program to be
cost-effective. As reported in the Application, the Company's inquiries with other utilties
and organizations that operate small commercial AlC cycling programs resulted in
widely varying reports about both the success of the programs and the quantity of peak
demand reduction that they were able to achieve. The average demand reduction
reported informally to Idaho Power by other utilties and organizations, and
subsequently provided to Staff through Staffs telephone calls to the Company, ranged
from about 1 kW to a high of about 9 kW per customer. Some utilties reported demand
reduction savings in terms of per ton of cooling and these results have a range of 0.25
kW to 0.51 kW per ton. According to the Northwest Energy Efficiency Allance
("NEEA"), typical AlC unit sizes for small commercial facilties in the Pacific Northwest
range from 5 to 15 tons.
As stated in the Application, because of the uncertainty of the actual, achievable
load reduction, and in order to obtain verifiable field data attributable to the program in
Idaho Powets service territory, Idaho Power proposed to operate the program as a pilot
for two AlC seasons. By operating its own pilot program, the Company can determine if
any customer segments wil deliver cost-effective peak demand reduction, can test
IDAHO POWER COMPANY'S REPLY COMMENTS - 2
customer option preferences, and can obtain real operational data about its own
system. If actual demand reductions are 2 kW or more, a viable customer segment is
identified, and pilot participants are satisfied, the Company could possibly continue to
implement a program. If the pilot shows that cost-effective demand reductions are not
possible, the program can end with the pilot.
Staff obviously feels that money should not be spent to operate a pilot program to
make this determination. Should the Commission disagree and authorize the Company
to move forward with the pilot program, the Company asks the Commission's
authorization that the pilot program be funded by the Energy Efficiency Rider funds.
DATED at Boise, Idaho, this 1 ih day of June 2009.
&W~DONOVAN E. WALKER
Attorney for Idaho Power Company
IDAHO POWER COMPANY'S REPLY COMMENTS - 3
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this 12th day of June 2009 I served a true and
correct copy of IDAHO POWER COMPANY'S REPLY COMMENTS upon the following
named parties by the method indicated below, and addressed to the following:
Commission Staff
Neil Price
Deputy Attorney General
Idaho Public Utilties Commission
472 West Washington
P.O. Box 83720
Boise, Idaho 83720-0074
.- Hand Delivered
U.S. Mail
_ Overnight Mail
FAX
.- Email NeiI.PriceCãpuc.idaho.gov
Ç/l/(L
Donovan E. Walker
IDAHO POWER COMPANY'S REPLY COMMENTS - 4