20130417Comments.pdf

WELDON B. STUTZMAN
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
P0 BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 3283
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Street Address for Express Mail:
472 W WASHINGTON
BOISE ID 83702-5918
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION OF )
IDAHO POWER COMPANY FOR APPROVAL ) CASE NO. IPC-E-13-04
OF ITS AGREEMENT WITH ENERNOC TO )
IMPLEMENT AND OPERATE A VOLUNTARY ) COMMENTS OF THE
COMMERCIAL DEMAND RESPONSE ) COMMISSION STAFF
PROGRAM. )
COMES NOW the Staff of the Idaho Public Utilities Commission, by and through its
Attorney of record, Weldon B. Stutzman, Deputy Attorney General, and in response to the Notice
of Petition and Notice of Modified Procedure issued in Order No. 32762 on March 13, 2013,
submits the following comments.
BACKGROUND
On March 7, 2013, Idaho Power Company filed a Petition requesting Commission approval
of Amendment No. 2 to the February 23, 2009 Demand Response Agreement between Idaho Power
and EnerNOC, Inc. The Agreement sets forth terms by which Idaho Power provides a demand
response (DR) program for its commercial and industrial customers known as the FlexPeak
Management Program. FlexPeak is a voluntary DR program targeting industrial and large
commercial customers that are capable of reducing their electrical energy loads for short periods
during summer peak load days. EnerNOC is responsible for developing and implementing all
STAFF COMMENTS 1 APRIL 17, 2013
marketing plans, securing participants, installing and maintaining equipment, tracking participation
and reporting results to Idaho Power. The Commission approved the five-year EnerNOC
Agreement in Order No. 30805 issued May 15, 2009, and later approved an amendment to clarify
terms of the Agreement in Order No. 31098.
In Case No. IPC-E- 12-29, Idaho Power requested authority to temporarily suspend the A/C
Cool Credit and Irrigation Peak Rewards DR programs because the Company's 2013 Integrated
Resource Plan (IRP) indicated no peak hour capacity deficits until July 2016. The case resulted in a
Settlement Stipulation in which all parties agreed to temporarily suspend both DR programs for
2013, provide participant continuity payments, and conduct workshops to discuss the Company's
DR programs in 2014 and beyond. The Commission approved the Settlement Stipulation in Order
No. 32776 on April 2, 2013. Idaho Power did not include the FlexPeak program in that case
because the Company does not have the ability to unilaterally suspend payment to EnerNOC prior
to the February 2014 contract expiration date.
STAFF REVIEW
Staff supports the Company's proposed amendment with EnerNOC. The modifications
reduce some of FlexPeak Management's operating and pricing parameters, thus lowering the cost to
ratepayers, without suspending the program for 2013. In conjunction with Case No. IPC-E-12-29,
this application modifies the Company's third and final DR program due to existing excess capacity
as identified in the 2013 IRP.
In the current filing, Idaho Power and EnerNOC have mutually and voluntarily renegotiated
the contract. Without the proposed modifications, the Company believes EnerNOC will secure
additional capacity and the program will cost approximately $3.0 - $3.3 million in 2013. The
changes to the contract could save ratepayers about $500,000, which would reduce costs to
approximately $2.5 - $2.8 million. The Second Amendment reduces:
1.the dispatch hours from 60 to 30,
2.the event days from 20 to 10,
3.the capacity payment paid to EnerNOC per kilowatt, and
4.the weekly nominated capacity bounds from 35-65 MW to 20-35 MW.
Idaho Power pays EnerNOC a pre-determined capacity price and a variable energy payment.
The capacity payment is based on the amount of reduction available during the program season and
the energy payment is based on the number of events called per season and the time length of each
STAFF COMMENTS 2 APRIL 17, 2013
event. EnerNOC compensates participants based on committed capacity and energy payments
(actual kWh reduction achieved during each event). Participants do not pay to participate or for
load control devices. EnerNOC receives a financial penalty if the weekly nominated capacity is
less than the lower capacity bound (35 MW in 2012).
In 2012, the Company called four events, totaling 14 hours. EnerNOC's weekly
commitments ranged from 29.6 MW to 38.8 MW. Staff calculated the average capacity reduction
from 2010-2012 at 35.8 MW, 38.7 MW, and 37 MW, respectively, and notes that the average
reductions are slightly above the proposed 35 MW capacity cap. Staff anticipates EnerNOC will
have little difficulty in meeting the proposed capacity cap.
The FlexPeak program operates under a five-year contract between Idaho Power and
EnerNOC that expires in February 2014. Compared to the temporary suspension of the A/C Cool
Credit and Irrigation Peak Rewards programs, FlexPeak is not as easily negotiable. The program
will be operational throughout the 2013 season. Consistent with Order No. 32776 that directed
stakeholder workshops to evaluate the A/C Cool Credit and Irrigation Peak Rewards DR programs,
Staff will work with interested parties in evaluating all three of the Company's DR programs for
2014 and beyond.
STAFF RECOMMENDATIONS
Staff recommends the Commission approve the Second Amendment to the Agreement
between Idaho Power and EnerNOC.
Respectfully submitted this day of April 2013.
Weldon B. Stutzman
Deputy Attorney General
Technical Staff: Nikki Karpavich
Donn English
i:umise:comments/ipcel 3.4wsnkde comments
STAFF COMMENTS 3 APRIL 17, 2013
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 17TH DAY OF APRIL 2013,
SERVED THE FOREGOING COMMENTS OF THE COMMISSION STAFF, IN CASE
NO. IPC-E-13-04, BY E-MAILING AND MAILING A COPY THEREOF, POSTAGE
PREPAID, TO THE FOLLOWING:
LISA D NORDSTROM TAM! WHITE
REGULATORY DOCKETS IDAHO POWER COMPANY
IDAHO POWER COMPANY P0 BOX 70
P0 BOX 70 BOISE ID 83707-0070
BOISE ID 83707-0070 EMAIL: [e-mail]
EMAIL: [e-mail]
[e-mail]
SECRETARY
CERTIFICATE OF SERVICE