20110217Reply Comments.pdf

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An IDACORP Company
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LISA D. NORDSTROM ~Lead Counsel . \~4~~r¡~~
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February 16, 2011
VIA HAND DELIVERY
Jean D. Jewetl, Secretary
Idaho Public Utilities Commission
472 West Washington Street
P.O. Box 83720
Boise, Idaho 83720-0074
Re: Case No. IPC-E-10-46
IN THE MATTER OF THE APPLICA TlON OF IDAHO POWER COMPANY
FOR APPROVAL OF REVISIONS TO THE IRRIGA TlON PEAK REWARDS
PROGRAM, SCHEDULE 23
Dear Ms. Jewell:
Enclosed for filing please find an original and seven (7) copies of Idaho Power
Company's Reply Comments in the above matter.
Very truly yours,
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Lisa D. Nordstro~
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Enclosures
1221 W. Idaho St. (83702)
P.O. Box 70
Boise, ID 83707
LISA D. NORDSTROM (ISB No. 5733)
DONOVAN E. WALKER (ISB No. 5921)
Idaho Power Company
P.O. Box 70
Boise, Idaho 83707
Telephone: [phone]
Facsimile: [phone]
Inordstromcæidahopower.com
dwalkercæidahopower.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 APPLICATION
OF IDAHO POWER COMPANY FOR
APPROVAL OF REVISIONS TO THE
IRRIGATION PEAK REWARDS
PROGRAM, SCHEDULE 23.
)
) CASE NO. IPC-E-10-46
)
) IDAHO POWER COMPANY'S
) REPLY COMMENTS
)
Idaho Power Company ("Idaho Power" or "Company"), by and through its
attorney of record, Lisa D. Nordstrom, and in response to the Notice of Modified
Procedure issued in Order No. 32158 and Comments filed on or before February 9,
2011, respectfully submits the following Reply Comments.
I. BACKGROUND
On December 10, 2010, the Company filed proposed revisions to its optional
demand response Irrigation Peak Rewards Program ("Program"), Schedule 23, to
become effective March 1, 2011. Although the Company's filng addressed several
Program design provisions, it was first and foremost developed to address prudency of
IDAHO POWER COMPANY'S REPLY COMMENTS - 1
incentive payments by ensuring that the Program's incentive structure was aligned with
the resource needs identified by the Company's 2011 Integrated Resource Plan ("IRP")
analysis. When the cost of demand response is aligned with needed capacity
reductions, Program participants, customers, intervenors, state utilty commissions and
the Company can be assured that incentive payments are wisely invested.
On February 9, 2011, the Idaho Public Utilties Commission ("Commission") Staff,
Idaho Irrigation Pumpers Association ("IIPA"), and the Idaho Conservation League
("ICL") filed comments on Idaho Power's proposed modifications in Case No. IPC-E-10-
46. In addition, several public comments were received from individual irrigation
customers.
II. THE COMPANY'S PURSUIT OF DEMAND RESPONSE
On page 6 of its Comments, the IIPA states that Idaho Power's proposed
changes go "far beyond the Program and impact the way IPC and the Commission view
all DSM programs - limits are being set for all DSM programs, not just the dispatchable
Program." Idaho Power strongly disagrees with IIPA's statement.
The Company has stated in numerous publications, filngs, and proceedings that
one of its major goals is to pursue all cost-effective energy efficiency and demand
response. The Company has not changed this policy. The results of the Company's
efforts to pursue cost-effective energy efficiency and demand response can be
assessed by its achievements since 2002. From 2002 to 2009, the average annual
increase in energy savings from Idaho Power's energy efficiency programs was more
than 40 percent. Since 2003, the Company has reduced its demand every year by
IDAHO POWER COMPANY'S REPLY COMMENTS - 2
investing in demand response programs. The Company has no intention of decreasing'
the amount of cost-effective, prudently incurred, energy savings or demand response.
It is not the Company's intent to limit demand response programs. To the
contrary, the Company wishes to develop an incentive structure for the Irrigation Peak
Rewards Program that wil optimize demand reductions and sustain participation in
response to the varying needs identified in the Company's IRP.
II. OPTIMIZING THE IRRIGATION PEAK REWARD PROGRAM
The IIPA implies that there is no difference between energy effciency and
demand response, continually referring to them collectively as Demand-Side
Management ("DSM") 1 resources. The Company's position has long been that energy
efficiency and demand response are fundamentally different? By offering DSM
programs to encourage customers to reduce energy consumption, the Company has
promoted energy efficiency. In comparison,. by offering programs that encourage
customers to turn off or not use equipment for short periods of time to meet extreme
capacity requirements, the Company has promoted demand response. When
1 "Demand-side Management" is a broad term that encompasses both energy efficiency and
demand response. The U.S. Energy Information Administration glossary defines DSM as: "The planning,
implementation, and monitoring of utility activities designed to encourage consumers to modify patterns of
electricity usage, including the timing and level of electricity demand. It refers to only energy and load-
shape modifying activities that are undertaken in response to utility-administered programs. It does not
refer to energy and load-shaped changes arising from the normal operation of the marketplace or from
government-mandated energy-efficiency standards. Demand-Side Management covers the complete
range of load-shape objectives, including strategic conservation and load management, as well as
strategic load growth."
2 Energy efficiency has been defined as "using less energy to provide the same or improved level
of service to the energy consumer in an economically efficient way." On the other hand, demand
response "entails customers changing their normal consumption patterns in response to changes in the
price of energy over time or to incentive payments designed to induce lower electricity use when prices
are high or system reliabilty is in jeopardy." Energy efficiency and demand response currently have
significant differences in how they are measured, what organizations offer them, how they are delivered
to customers, and how they are rewarded in the marketplace. Federal Energy Regulatory Commission
Staff, National Action Plan on Demand Response dated January 2010, p. 21.
IDAHO POWER COMPANY'S REPLY COMMENTS - 3
considering demand response, there is an optimum amount of demand reduction that
can be realized from demand response programs and incorporated onto its electrical
system. The fact that the IIPA states "It is not the position of the IIPA that there is no
limit to the need for DSM. . ." confuses the distinction between energy efficiency and
demand response. IIPA Comments at 6.
Both the Commission Staff and the IIPA indicate that the Company should
attempt to obtain as much demand response resources as possible. On page 9 of its
Comments, Staff states that the Company should not limit participation and it should
". . . not only accept, but promote participants in the Program in order to achieve peak
load reduction. . . . ." The Company's ongoing goal has been to obtain the appropriate
amount of peak reduction through demand response resources in order to satisfy the
needs indicated in the Company's IRP. To say the Company should obtain all demand
response resources possible is analogous to saying it should build peaking plants
whether they are needed or not. The Company believes that demand response
programs should be optimally sized to meet the projected system needs and not
limitlessly increased because there are willng participants.
Some comments explicitly state or otherwise intimate that the Company is
substituting supply-side resources for demand response resources. This is simply not
true. Demand response programs are intended to defer or avoid the need for peaking
resources. Supply-side resource investments are typically "lumpy" and when integrated
into the electrical system, they wil temporally reduce the need for demand response.
The Company's proposal endeavors to price demand response in such a way that the
incentive fluctuates rather than participation.
IDAHO POWER COMPANY'S REPLY COMMENTS - 4
With Idaho Power's proposed changes, the Irrigation Peak Rewards Program
remains cost-effective; however, the Company believes that its investment of customer
funds in DSM programs should be optimized as welL. By better aligning the cost of the
resource with the demand reduction actually received, the Company is more
responsibly investing customer DSM program funds and ensuring long-term
optimization of demand response resources.3
The IIPA also states, ". . . if it isn't broke, there is no need to fix it." IIPA
Comments at 3 and 14. Idaho Power does not consider the Program "broke." The
Company is committed to a continuous improvement process for all of its DSM
programs. As stated in paragraph 9 on page 6 of the Memorandum of Understanding
for Prudency Determination of DSM Expenditures, dated January 25, 2010, "Utilties are
encouraged to continually review these programs and make appropriate program
improvements." The Company believes that the proposed changes to the Irrigation
Peak Rewards Program better utilze customers' investment by operating the Program
in such a way that the Company only pays the variable portion of the incentive for the
load reduction that is needed and realized.
On pages 1 and 2 of the IIPA's Comments, a comparison is made between the
value of demand response and market energy prices. The IIPA states that the
Company should use the Program to its fullest and sell excess energy into the market.
IIPA Comments at 10. This does not make economic sense considering that the price
of demand response is approximately $850 per megawatt-hour ("MWh") (assuming 60
3 Optimization of cost-effectiveness has been previously touted in the DSM context. See
testimony of Lynn Anderson, Case No. IPC-E-08-10, Tr. at 1208-9, ". . . it is just as important that the
DSM alternatives as implemented be as cost-effective as practicable from the utilty perspective. . .. In
other words, it is not prudent to pay more for a DSM resource than is necessary."
IDAHO POWER COMPANY'S REPLY COMMENTS - 5
hours of operation annually) while market energy prices have recently been
approximately $40 per MWh on peak. The IIPA states on page 9, ". . . they (irrigation
customers) sign up with the expectation that they wil be interrupted 60 hours per
season - nothing else makes economic sense." This is difficult for Idaho Power to
accept given the anecdotal information that the Company has received indicates that
many participants' crops cannot withstand 60 hours of interruption without damage.4
Moreover, participation has increased in part because irrigators have realized that the
Company would only use the full 60 hours in very extreme conditions.
The purpose of demand response on the Idaho Power system is to fill a potential
peaking need that the IRP identifies at extreme weather conditions during low water
years. This rare instance causes a deficit between resources available and potential
customer loads. The IRP includes market purchases to the extent that the Company
has transmission capacity available to get the energy onto its system. But even with
market purchases and utilzing all existing supply side resources, the IRP shows there
are stil deficits. It is these potential deficits that demand response has been designed
to fill more economically than building additional gas fired peaking plants.
iv. ATTEMPTED COLLABORATION
The IIPA maintains that the Company made these proposals "out-of-the-blue"
without an appropriate level of analysis. IIPA Comments at 6. Idaho Power would like
to stress that it originally introduced the concept of variable pricing and the need for the
8:00 p.m. to 9:00 p.m. load reduction in the fall of 2009 during discussions with the IIPA
about Program changes for 2010. At that time, the IIPA did not support these changes.
4 Mr. Ketterling's quote on page 3 of the IIPA's Comments that his participation in the program
"may cost me some crop" alludes to this concern.
IDAHO POWER COMPANY'S REPLY COMMENTS - 6
In November of 2010, prior to the Company's determination of its proposed
changes to the Program, the Company initiated a conference call and workshop with the
IIPA and other irrigation customers. The intent of the workshop was to discuss potential
changes, answer questions, obtain input, and present the additional demand response
analysis that the Company had performed. After this workshop, Idaho Power sent out a
list of proposed changes to the IIPA and scheduled a follow-up meeting in December
2010. The December meeting was intended to be a working meeting with the IIPA to
agree on proposed Program changes that could be supported by both the Company
and IIPA. However, due to the fact that it might affect their ongoing case with Rocky
Mountain Power, the IIPA decided that negotiations on proposed incentive levels and
other design issues were not appropriate. Despite its efforts to the contrary, the
Company was left to file its proposed Program modifications with limited input from the
IIPA.
v. COMMENTS ON PROPOSED PROGRAM MODIFICATIONS
A. Incentive Payment Structure.
Staff Comments. Although Staff supports changing the existing incentive
structure from a fixed to variable incentive payments for the Dispatchable Options, Staff
does not support the Company's proposed levels of fixed and variable payments.
Therefore, Staff does not recommend changes to the Program's current incentive
structure. Staff Comments at 3 and 9.
IIPA Comments. The IIPA states that the proposed change in incentive structure
wil reduce participation in the Program and they do not support the Company's
proposed incentive structure for participants of the Dispatchable Option. IIPA
IDAHO POWER COMPANY'S REPLY COMMENTS - 7
Comments at 13 and 20. Assuming that the Commission wishes to lower the credit paid
to Peak Reward participants, the IIPA offers that the credit could be reduced from
$32/kilowatt ("kW") down to $25/kW (based on 50 percent load factor) if the hours of
interruption are reduced from 60 hours per season to 28 hours per season (7 days of
interruption). Id. at 14.
ICL Comments. The ICL supports the Company's proposal to move from a 100
percent fixed incentive payment to a fixed and variable payment as a means to
minimize costs to "ratepayers while maximizing the value to Idaho Power." ICL
Comments at 3.
Company's Position. The Company agrees with the commentors that the
Company's proposed 40 percent fixed and 60 percent variable incentive may be
considered a significant change from the current incentive structure. However, Idaho
Power believes that having a fixed and variable incentive is important to ensure that the
incentive structure remains aligned with the annual capacity needs of the Company, that
the Program is used at the appropriate times, and that it brings balance and long-term
value to all Idaho Power customers and Program participants.
Staff points out that it supports changing the incentive to have fixed and variable
components, but it does not agree with the percentages the Company proposed. Staff
instead proposes that a more appropriate guideline for determining the incentive level
would be the proportion of fixed costs compared to variable costs of a simple-cycle
peaking plant. Staff Comments at 5. If used, this ratio would result in approximately 50
percent fixed costs and 50 percent variable costs based on the Company's 2011 IRP
analysis. These calculations, which Idaho Power has included on Attachment NO.1,
IDAHO POWER COMPANY'S REPLY COMMENTS - 8
demonstrate that the forecasted 30-year levelized capital costs are $159 per MWh while
the forecasted 30-year levelized variable costs are also $159 per MWh (includes non-
fuel operation and maintenance, fuel expense, and emission adders) at an assumed
525 hours of operation per year. This calculation assumes a 6 percent capacity factor
as identified in the Company's 2011 IRP analysis.
Based on this information, Idaho Power can mathematically support an incentive
level of 50 percent fixed incentive payment and 50 percent variable incentive payment
with the. variable portion based on the number of hours a participant is interrupted
through the Program. Idaho Power believes this newly proposed incentive payment
structure wil address concerns that the fixed incentive payment should be high enough
to attract participants while setting the variable incentive payment high enough to make
interruptions in participants' operations worthwhile from their perspective. These
incentive levels are difficult to optimize for each participant, the variable incentive should
be high enough that the Company wil not dispatch the Program when reasonably
priced energy is available on the market and transmission capacity is available to get
energy into the Company's system.
However, if the Commission determines that neither the 40/60 nor 50/50 level of
fixed to variable incentive payments is appropriate, the Company would urge the
Commission to not abandon the fixed to variable incentive structure completely. Should
the Commission agree that a fixed to variable structure is appropriate, but wish to
mitigate initially the impact to participants, the Company suggests that a logical
minimum variable payment basis would be to set the variable portion of the incentive at
or above the 30-year levelized variable cost of a simple-cycle combustion turbine, which
IDAHO POWER COMPANY'S REPLY COMMENTS - 9
is $0.159 per kWh or $159 per MWh (see Attachment No.1). Using this approach, the
variable incentive amount would result in a $24 per kW fixed incentive and a ratio of 75
percent fixed to 25 percent variable. While not the Company's preferred incentive
structure, this alternative structure would result in a variable dispatch cost that would
create an economic disincentive for the Company to use the Program when reasonably
priced market energy is available or when existing Idaho Power peaking generation
resources are available for dispatch.
Idaho Power does not support IIPA's proposal to reduce the incentive to $25 per
kW or to reduce the hours of interruption. Idaho Power's proposed incentive structure is
designed to better align the need for demand response with the cost of demand
response, not to simply reduce costs and further limit the hours of dispatch availabilty of
the Program.
B. Variable Payment Made by Check at End of Season.
Staff Comments. Staff suggests that if a variable payment is approved, the
Company should pay the variable portion "as quickly as possible following the end of
the Program season." Staff Comments at 5.
IIPA Comments. If a variable incentive payment is approved, IIPA recognizes
that it may be necessary to pay this portion after the Program season. However, it feels
that 30 days should allow sufficient time to make the payments rather than the 60 days
after the August 15 Program end date that was proposed by Idaho Power. IIPA
Comments at 23.
ICL Comments. The ICL does not address this proposed program modification in
its Comments.
IDAHO POWER COMPANY'S REPLY COMMENTS - 10
Company's Position. Idaho Power believes that paying the variable portion of the
incentive at the end of the Program's season is the most viable way of making sure
participants are paid accurately. In consideration of both Staffs and the IIPA's concerns
on this payment methodology, the Company wil agree to shorten the payment of the
variable incentive time frame from 60 days to 45 days after the end of the Program's
season. Any period shorter than 45 days is unworkable given that meter data
necessary to calculate the variable incentive is not available unti 30 days after the
Program end date.
c. Dispatchable Option 3 Modifications.
Staff Comments. Staff agrees with the Company' proposal to have participants
nominate their load and to pay an opt-out penalty under a fixed and variable incentive
structure. Staff Comments at 6. However, Staff does not support the Company's
proposed baseline calculation and "disagrees that the proposal would result in a more
accurate estimate than the current method." Id. at 7. Staff instead suggested that the
Company consider using the day prior to the event notification, by averaging
participants' usages over the same period in which the actual event occurred. If two
consecutive event days were called, baseline could be calculated using the day prior to
the first event notification, by averaging usage of the full time period both events
occurred. Id.
IIPA Comments. The IIPA does not support the Company's proposal to require
participants to nominate their load reduction, charge an opt-out penalty, or implement a
new method to calculate a baseline. IIPA suggests that the existing language in the
Program's provisions be modified to reflect that the "24-hour period where the maximum
IDAHO POWER COMPANY'S REPLY COMMENTS - 11
demand wil be measured should be the 24 hours prior to the announcement of the
curtailment event as opposed to prior to the event itself." IIPA Comments at 20.
ICL Comments. ICL supports the Company's proposed modifications to require
that Dispatch Option 3 participants to nominate their load and for the Company to
implement an opt-out penalty. ICL believes these changes wil ensure a "cost-effective,
sustainable program." ICL Comments at 3.
Company's Position. As proposed, Dispatchable Option 3 participants must
nominate the minimum amount demand they are confident they can provide. This is
important to allow Idaho Power to better plan its capacity during interruptions, but wil
not limit the ability to participate. For example, if the Company called an event, the
Option 3 participant wil be paid for the entire load reduction provided and the load
reduction would affect both the fixed and variable portions of their incentive. If a
customer was concerned about their abilty to reduce load, they could participate but
nominate OkW and their fixed and variable incentive would reflect what loads they
actually turned off during dispatched events. In effect, this nominated kW is used to
determine the participant's incentive when no events are called and the nominated kW
is the basis for the calculation of the opt-out penalty. It is not the Company's intent to
reduce Dispatch Option 3 participants' flexibility.
With regard to changing the baseline for Dispatchable Option 3 participants, the
Company agrees to adopt a methodology similar to what was proposed by both the IIPA
and Staff, with one small clarification. The Company believes it is reasonable to use the
maximum demand in the prior 24 hours preceding 2:00 p.m. of the notification day.
Pursuant to the Program's terms, the Company currently notifies participants of events
IDAHO POWER COMPANY'S REPLY COMMENTS - 12
prior to 4:00 p.m. the day prior to an event. However, the Company can (and does)
begin earlier to ensure all participants are notified by 4:00 p.m.
D. Opt-out Penalty.
Staff Comments. Staff found the proposed change to the opt-out penalty to be
lower and easier to calculate. Therefore, Staff supports the Company's proposal to
change the penalty to $1.00 per kW. Staff Comments at 7.
IIPA Comments. IIPA recommends adoption of the change to the opt-out penalty
stating that it is easier to calculate and "is essentially fixed" as compared to the current
$0.005 per kWh rate. IIPA Comments at 22.
ICL Comments. ICL supports opt-out penalties in general as a means to "ensure
the amount of load curtailment Idaho Power expects to have available actually comes to
fruition." Although supportive of simplifying the calculation, the ICL indicated it did not
"have the expertise to determine if the specific monetary amounts are sufficient." ICL
Comments at 4.
Company's Position. Consistent with the other parties, the Company encourages
the Commission to accept the proposed change to the opt-out penalty.
E. Extended Interruption Period from 8:00 p.m. to 9:00 p.m.
Staff Comments. Staff supports the extended interruption period. However, Staff
suggests that it be a mandatory requirement of the Program in order to "fully achieve
the operational impact of the Program." If adopted, the Company should consider
increasing the incentive if the participation level drops and it is cost-effective to do so.
Staff Comments at 8.
IDAHO POWER COMPANY:S REPLY COMMENTS - 13
IIPA Comments. Although the IIPA believes that this extended interruption
period "is not well thought out and is not economically designed to bring a strong
response, there is no major harm to the dispatchable Program by the adoption of such a
provision." IIPA Comments at 22.
ICL Comments. ICL states that the extended interruption period wil allow the
Company to better match its system peaks. Although the ICL supports the increased
variable incentive for participants choosing this option as necessary to attract
participants in the short-term, it believes the "bonus incentive" should no longer be
needed as the Program matures. ICL Comments at 2.
Company's Position. Implementation of the "Extended Interruption" option wil
help ensure Idaho Power can reduce loads across the entire peak period and provide
participants an opportunity to receive a higher incentive. As a result of its experience
operating the Irrigation Peak Rewards Program in 2009 and 2010, the Company found
that at least some of the capacity must be available in the 8:00 p.m. to 9:00 p.m. hour
for demand response to fully reduce a system peak. However, the Company does not
propose to make this option mandatory in order to maintain higher participation levels
as recommended by Staff. Idaho Power representatives have received feedback while
working with irrigation customers indicating some participants would definitely not
participate if they thought the Company would be able to interrupt them after 8:00 p.m.
The goal of the Company in dispatching demand response is to flatten the
system load throughout the peak hours. As the IIPA points out on page 21 of its
Comments, the 3:00 p.m. to 4:00 pm peak is as high as the 8:00 p.m. to 9:00 p.m. peak.
Idaho Power believes that approval of the extended interruption period from8:00 p.m. to
IDAHO POWER COMPANY'S REPLY COMMENTS - 14
9:00 p.m. wil allow the Company to better address the entire peak period because the
available hours wil be inclusive enough to enable the Company to decrease both the
early and later peaks by varying interruption periods throughout the Program's hours of
operation.
F. Annual Test Event.
Staff Comments. Staff supports the Company's proposal to include one test
event per season. Staff believes the test event is important to test reliabilty and
timeliness of interruptions. Staff Comments at 8.
IIPA Comments. The IIPA recommends that the Commission reject the
Company's proposal for an annual test event stating that all interruptions should count
toward the full incentive payment. IIPA Comments at 16.
ICL Comments. ICL supports the proposed annual test event and states that it is
a "prudent and effective strategy to ensure reliabilty." ICL Comments at 3.
Company's Position. Idaho Power proposes that one event be included as part
of the fixed payment, which is essential to remove any disincentive for the Company to
use the Program at least once during the Program season to monitor electronic
interruption systems and to assess Program performance. Idaho Power believes the
time frame of this event should be at the Company's discretion.
G. Limiting Program Participation.
Staff Comments. Staff recommends the Commission deny the Company's
proposal to add language limiting the Program participation based on need for peak
load reduction. Pointing to the Program's high long-term benefit/costs ratio, Staff
IDAHO POWER COMPANY'S REPLY COMMENTS - 15
indicates that Idaho Power should promote participation to achieve peak load reduction
over the longer term as long as the Program's B/C ratio is greater than one. Staff at 9.
IIPA Comments. The IIPA strongly opposes adoption of additional tariff language
limiting the size of "DSM" programs. IIPA Comments at 8.
ICL Comments. ICL does not address this proposed change in their comments.
Company's Position. Idaho Power's proposal to add "clarifying language" to the
tariff was intended to emphasize that the Company may limit participation in an effort to
better align the Program with capacity needs identified in the Company's IRPs.
However, in the larger context of the Program's tariff, the proposed clarifying language
is not necessary.
H. Public Comments Generally.
A number of the public comments refer to the substantial investments made to
their irrigation systems in order to participate in the Program. It should be noted that the
Company has never encouraged customers make substantial modifications to their
systems in order to participate in the Program. In fact, there is a program requirement
that "each Customer also agrees to not increase for the sole purpose of participating in
the Program the capacity, horsepower ("HP") or size of the irrigation system served by
the Company." IPUC Tariff No. 29, Schedule 23-1, paragraph 4. There is no guarantee
of multi-year participation; the Program operates under a one-year contract with each
participant, which objectively should discourage participants from making long-term
investments in order to participate.
IDAHO POWER COMPANY'S REPLY COMMENTS - 16
VI. CONCLUSION
There are few, if any, utilties of Idaho Power's size that have the experience with
or the amount of demand response that the Company has. Idaho Power has worked for
years with the IIPA, Staff, the Pacific Northwest Demand Response Project, the Energy
Efficiency Advisory Group, and others to design, implement, and refine its programs.
The Company's purpose in filng this case was to optimize investment of
customer funds in demand response resources by more closely aligning the need and
realization of these resources with the costs. The Company believes that its original
proposal to modify the Irrigation Peak Rewards Program would maintain participation
and begin to match demand response reduction levels to the needs of its electrical
system. That being said, the Company noted its agreement above with several
changes suggested by the commentors. The Company requests the Commission adopt
its proposed program revisions as modified above in Section V, A (incentive Structure),
B (timing of variable payment check), and C (Option 3 24-hour baseline).
DATED at Boise, Idaho, this 16th day of February, 2011.
¿J!.flb~
LISA D. NORD TROM
Attorney for Idaho Power Company
IDAHO POWER COMPANY'S REPLY COMMENTS - 17
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 16th day of February, 2011, 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
Weldon B. Stutzman
Deputy Attorneys General
Idaho Public Utilties Commission
472 West Washington
P.O. Box 83720
Boise, Idaho 83720-0074
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U.S. Mail
_ Overnight Mail
FAX
-l Email Weldon.StutzmanCâpuc.idaho.gov
Idaho Irrigation Pumpers Association, Inc.
Eric L. Olsen
RACINE, OLSON, NYE, BUDGE &
BAILEY, CHARTERED
201 East Center
P.O. Box 1391
Pocatello, Idaho 83204-1391
Hand Delivered
-lU.S. Mail
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FAX
-l Email eloCâracinelaw.net
Anthony Yankel
Yankel & Associates, Inc.
29814 Lake Road
Bay Vilage, Ohio 44140
Hand Delivered
-lU.S. Mail
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FAX
-l Email tonycæyankel.net
Idaho Conservation League
Benjamin J. Otto
Idaho Conservation League
710 North Sixth Street
P.O. Box 844
Boise, Idaho 83701
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-2 U.S. Mail
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FAX
-2 Email bottoCâidahoconservation.org
¿t¡l&:~LISA D. NÕDS ÕM
IDAHO POWER COMPANY'S REPLY COMMENTS - 18
BEFORE THE
IDAHO PUBLIC UTiliTIES COMMISSION
CASE NO. IPC-E-10-46
IDAHO POWER COMPANY
ATTACHMENT NO.1
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