20130311Comments.pdf

Benjamin J. Otto (ISB No. 8292)
710 N 6th Street
Boise, ID 83701
Ph: [phone] x 12
Fax: [phone]
[e-mail]
Attorney for the Idaho Conservation League
I,w MAR 1.21
UTtUT
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE )
APPLICATION OF THE IDAHO CASE NO. IPC-E-12-29 POWER COMPANY FOR AUTHORITY )
TO TEMPORARILY SUSPEND ITS A/C COMMENTS OF THE IDAHO COOL CREDIT AND IRRIGATION CONSERVATION LEAGUE PEAK REWARDS DEMAND )
RESPONSE PROGRAMS )
The Idaho Conservation League (ICL) recommends the Commission approve the
Stipulation. Over the last decade, demand response programs have become sizable resources --
more than 30,000 Idahoans participate in the A/C Cool Credit program alone. Collectively, the
programs provide over 350 MW of capacity to mitigate peak demands. After a decade of
development and millions of dollars invested, ensuring the long-term viability of this resource
serves the public interest. While stakeholders examine the programs over the next year, allowing
Idaho Power to incur reasonable maintenance expenses will help ensure the programs remain
viable. The Stipulation protects customers by ensuring "recovery of reasonable infrastructure
costs will be addressed as part of the Commission's prudency review process."' And customers
benefit by reducing the incentive costs below current base levels in the Power Cost Adjustment --
for example, A/C Cool Credit PCA impact will drop from $769,0000 to about $90 - $105,000.2
Because it protects the public interest while establishing a process to ensure the long-term
viability of the demand response programs, ICL recommends the Commission approve the
Stipulation.
A critical part of ensuring the long-term viability of the A/C Cool Credit program is
maintaining customer participation levels. For this program, participation matters since each
'Stipulation at 5 9, page 4.
2 See Exhibit 1, IPC Response to Staff Request #19. The $90,000 - $105,000 is an estimate of the
continuity payment of $3 per customer times 30,000 —and 35,000 customers.
ICL Comments 1 March 11, 2013
IPC-E- 12-29
home provides a small amount of demand reduction? ICL supports providing $3 continuity
payment to encourage customers to remain in the program. This payment is a tangible showing
Idaho Power intends to maintain the program, acknowledges customer participation, and keeps
participants engaged with the program during the upcoming year. Idaho Power anticipates
spending about $650,000 to maintain the system during the suspension period." An additional
$100,000 in continuity payments is a reasonable expense to encourage customer participation.
ICL looks forward to reviewing the pricing and operations of the demand response
programs during the second phase of this proceeding. As these programs mature, the operations
and incentive levels must adapt to maximize the value for Idaho Power and customers. During
2012, impact evaluations of the A/C Cool Credit program show that matching cycling rates to air
temperature can produce more energy savings making the programs more cost.-' Phase two
provides a forum to review these types of changes to operations and adjust incentive structures
appropriately. By approving the Stipulation, the Commission can help maintain current
program capacity and establish a forum to maximize customers' investment in demand response
programs.
DATED, the 11d day of March 2013,
Respectfully submitted,
Benjamin J. Otto
Idaho Conservation League
See Exhibit 1, Idaho Power Response to Staff Request #31. (Showing Max kW Reduction per unit I from 0.25 to 1.09.)
4 Direct Testimony of Theresa Drake at 14.
See Exhibit 1, Idaho Power Response to Staff Request # 31.
ICL Comments 2 March 11, 2013
IPC-E-12-29
Benjamin J. Otto (ISB No. 8292)
710 N 66' Street
Boise, ID 83701
Ph: [phone] x 12
Fax: [phone]
[e-mail]
Attorney for the Idaho Conservation League
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE )
APPLICATION OF THE IDAHO CASE NO. IPC-E-12-29 POWER COMPANY FOR AUTHORITY )
TO TEMPORARILY SUSPEND IT'S A/C COMMENTS OF THE IDAHO COOL CREDIT AND IRRIGATION CONSERVATION LEAGUE PEAK REWARDS DEMAND )
RESPONSE PROGRAMS )
Exhibit 1
Idaho Power Company Response to Staff Request #19 and #31
ICL Comments March 11, 2013
Exhibit 1
IPC-E-12-29
RESPONSE TO REQUEST NO. 19: The Company's current base rates include a
normalized" level of demand response incentive recovery of $1 1.3 million from which
deviations will be tracked through the 2013-2014 Power Cost Adjustment ("PCA"). The
Company has not yet forecast the level of demand response incentive payments that will
be included in the 2013-2014 PCA filing that will be made on April 15, 2013. The
program breakout for the normalized recovery in base rates is:
AC Cool Credit: $769,647.48
Flex Peak Management $1,993,222.50
Irrigation Peak $8.489.395.50
Total: $11,252,265.48
The response to this Request was prepared by Scott Wright, Regulatory Analyst
II, Idaho Power Company, in consultation with Lisa D. Nordstrom, Lead Counsel, Idaho
Power Company.
ICL Comments 1 March 11, 2013
Exhibit 1
IPC-E-12-29
RESPONSE TO REQUEST NO. 31:
Date % Cycling
Boise
Metro
Temp
Twin
Falls
Pocatello
Temp
Data
source
Max kW
Reduction /
unit
June 2l,2012 65% 950 890 AM! 0.5
July 02, 2012 100% (1 hr) 950 890 AM! 0.25
July 11, 2012 60% 990 940 AM! 0.33
July 12, 2012 60% 1060 990 AM! 1.09
July 19, 2012 65% 1040 950 AM! 0.95
July 25, 2012 50% 97° 950 AM! 0.37
July 31, 2012 70% 970 940 AM! 0.89
August 13, 2012 50% 970 930 AMI 0.4
August 16, 2012 75% 930 920 AM! 0.8
August 20, 2012 65% 940 850 AM! 0.57
August 22, 2012 100% (1 hr) 90 0 870 AM! 0.85
It should be noted, the average load reduction across events for 2012 does not
represent the potential peak load reduction. In 2012, Idaho Power contracted with PEC!
to conduct research associated with the load reduction for the A/C Cool Credit program.
Under the plan developed by PEC!, Idaho Power experimented with various cycling
strategies at various temperature bins and specifically did not cycle on some days to be
used as control days. The entire study conducted by PEC! will be included in Idaho
Power's Demand-Side Management 2012 Annual Report, Supplement 2: Evaluation filed
with the Commission on March 15, 2013. Because the data source for the table above was
AM! hourly load data, the kilowatt ("kW") reduction per unit column is based on hourly
data.
The response to this Request was prepared under the supervision of Theresa
Drake, Customer Relations and Energy Efficiency Manager, Idaho Power Company, in
consultation with Lisa D. Nordstrom, Lead Counsel, Idaho Power Company.
ICL Comments 2 March 11, 2013
Exhibit 1
!PC-E-12-29
CERTIFICATE OF SERVICE
I hereby certify that on this 11th day of March 2013,! delivered true and correct
copies of the foregoing COMMENTS to the following persons via the method of service
noted:
Hand delivery:
Jean Jewell
Commission Secretary (Original and seven copies provided)
Idaho Public Utilities Commission
427 W. Washington St.
Boise, ID 83702-5983
Electronic Mail:
Lisa D. Nordstrom
Courtney Waites
Tim Tatum
Idaho Power Company
P.O. Box 70
Boise, ID 83707
[e-mail]
[e-mail]
[e-mail]
[e-mail]
Eric Olsen
Racine, Olsen, Nye, Budge & Bailey,
Chartered
P.O. Box 1391
Pocatello, ID 83204
[e-mail]
Anthony Yankel
29814 Lake Road
Bay Village, OH 44140
[e-mail]
Ken Miller
Clean Energy Program Director
Snake River Alliance
Box 1731
Boise, ID 83701
[e-mail]
a,4
Benjamin J. Otto
Certificate of Service March 11, 2013
IPC-E-12-29