20140314Reply Comments.pdf

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DONOVAN E. WALKER
Lead Counsel
[e-mail]
March 14,2014
VIA HAND DELIVERY
Jean D. Jewell, Secretary
ldaho Public Utilities Commission
472 West Washington Street
Boise, ldaho 83702
Re: Case No. IPC-E-13-21
Capacity Deficiency Period Utilized in SAR Methodology - ldaho Power
Company's Reply Comments
Dear Ms. Jewell:
Enclosed forfiling in the above matterare an originaland seven (7) copies of ldaho
Power Company's Reply Comments.
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Enclosures
Very truly yours,&,/<
Donovan E. Walker
1221 W. ldaho 5t. (83702)
P.O. Box 70
Boise, lD 83707
DONOVAN E. WALKER (lSB No. 5921)
JULIA A. HILTON (lSB No. 7740)
ldaho Power Company
1221West ldaho Street (83702)
P.O. Box 70
Boise, Idaho 83707
Telephone: [phone]
Facsimile: [phone]
dwal ker@ idahopower. co m
ih i lto n@ idahopower. com
Attorneys for ldaho Power Company
IN THE MATTER OF IDAHO POWER
COMPANY'S APPLICATION FOR APPROVAL
OF ITS CAPACITY DEFICIENCY PERIOD TO
BE UTILIZED IN THE COMPANY'S SAR
METHODOLOGY.
a ,. ._il.. r_ i ,,i
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
CASE NO. IPC-E-13-21
IDAHO POWER COMPANY'S
REPLY COMMENTS
ldaho Power Company ("ldaho Powe/' or "Company") respectfully submits the
following Reply Comments in response to Comments filed by the ldaho Public Utilities
Commission ("Commission") Staff ("Staff') on February 23,2014.
I. PROCEDURAL HISTORY AND INTRODUCTION
ln December 2012, the Commission directed that this case be initiated outside of
the lntegrated Resource Plan ('lRP") filing for the establishment of the capacity
deficiency period to be utilized in the surrogate avoided resource ("SAR') avoided cost
rate methodology:
[W]e find it reasonable and fair to subject each utility's
determination of capacity deficiency to further scrutiny.
Therefore, when a utility submits its lntegrated Resource
IDAHO POWER COMPANY'S REPLY COMMENTS - 1
Plan to the Commission, a case shall be initiated to
determine the capacity deficiency to be utilized in the SAR
Methodology. The capacity deficiency determined through
the IRP planning process will be the starting point, and wi!!
be presumed to be correct subject to the outcome of the
proceeding.
Order No. 32697, p. 23. The Commission also directed in that Order that inputs from
the Company's IRP will remain fixed between IRP cycles, with the exception of the load
forecast and the natural gas forecast-which is to be updated annually by October 15 of
each year. Order No. 32697, p. 22; Order No. 32802. The Commission also directed
that Public Utility Regulatory Policies Act of 1978 ("PURPA') contracts that have
terminated or expired, as well as any new long-term contracts that have been signed,
be included in the utility's load and resource balance. Order No. 32697, p.22.
ldaho Power filed its 2013 IRP on June 28, 2013.1 On October 15, 2013, the
Company filed its updates to the IRP's avoided cost rate inputs, including an updated
load forecast, updated natural gas forecast, and an updated list of new and terminated
PURPA contracts and long-term power purchase agreements. The Commission
subsequently approved these updates in Order No. 32941. Idaho Power filed its
Application in this case on November 4, 2013, seeking an update to the capacity
deficiencies identified in the 2013lRP for purposes of avoided cost rate determinations
with a first deficit occurring in July 2021.
On February 28, 2014, Staff filed Comments recommending a first deficit year of
2016. ldaho Power now files its Reply Comments addressing Staff's criticisms and
assumptions and reiterating its request for establishment of a first capacity deficit
occurring in July 2021 for purposes of avoided cost rate determinations.
t ldaho Power's 2013 IRP was recently accepted by the Commission on February 24, 2014.
Order No. 32980.
IDAHO POWER COMPANY'S REPLY COMMENTS - 2
II. COMMENTS
ldaho Power set forth three identified capacity deficiency positions in its
Application for this case: (1) the capacity deficiencies identified in the 2013lRP; (2) the
2013 IRP capacity deficiencies updated to include the updated load forecast, natural
gas forecast, and new and terminated contracts from Case No. IPC-E-13-18; and (3)
the updated 2013 IRP capacity deficiencies, including up to 440 megawatts ("MW") of
demand response ("DR") from the settlement agreement ("Settlement Agreement") in
Case No. IPC-E-13-14.
Staff was highly critical of, and disagreed with, the Company's inclusion of up to
440 MW of DR. lnstead, Staff recommended including only 170 MW of DR for
determining the capacity deficiency for avoided cost rate pricing. Staff Comments, p. 8.
Staff stated:
ldaho Power's inclusion of demand response in its load
resource balance assumes it can reliably and immediately
provide 440 MW continually throughout the entire 2O-year
planning period. Staff believes this contradicts the basis of
the Commission-approved settlement agreement, the likely
effect of the program modifications included in the
settlement, and is not justified by the Company's responses
to discovery in this case. Staff maintains that the most
reasonable estimate of the capacity provided by ldaho
Power's demand response portfolio is 170 MW.
Staff Comments, p. 4.
As explained below, it is Staff's arbitrary limitation of DR capacity to 170 MW that
"contradicts the basis" of the Settlement Agreement, is inconsistent with the Settlement
Agreement and the accepted 2013 IRP, and results in an overpayment of capacity in
the PURPA avoided cost rate to the detriment of customers.
IDAHO POWER COMPANY'S REPLY COMMENTS - 3
A. Staff's Assumption Limitins DR Capacitv to Onlv 170 MW ls Not Gonsistent
with the Settlement Asreement.
Staff criticizes the Company for including 440 MW of DR in its Peak-Hour
Surplus/Deficit Charts. Staff contends that the inclusion of 440 MW is inconsistent with
the outcome of the Settlement Agreement entered into in Case No. IPC-E-13-14,
approved by the Commission in Order No. 32923. Staff contends that the appropriate
estimate of capacity to be achieved after the Settlement Agreement is 170 MW. Staff's
position incorrectly equates the value (the amount the Company can spend on demand
response) with the capacity (the amount of demand response the Company is requlred
to accept). The Settlement Agreement states:
The Company musf:
i. Use existing demand response resources when possible.
This includes using, to the extent possible, current demand
response equipment owned or available to ldaho Power and
participating demand response customers, which currently
represents approximately 400 megawatts ("MW") of
potential demand response capacity
vi. Calculate the avoided cost used for demand response
by using the avoided capacity cost of a 170 MW single cycle
combustion turbine ("SCCT') multiplied by the effective load
carrying capacity (.ELCC"), measured over 20 years, plus
the corresponding deferred energy savings for 60 program
hours.
Case No. IPC-E-13-14, Settlement Agreement, p. 3 (emphasis added).
In the DR workshops leading up to the Settlement Agreement, the participants
expressed a desire to preserve customer participation in and infrastructure used for
ldaho Power's DR programs for the longterm, and acknowledged that this meant
incurring DR costs even in years when the IRP did not demonstrate a need for such
IDAHO POWER COMPANY'S REPLY COMMENTS - 4
costs. The participants ultimately justified the value of incurring costs in such years by
reasoning that, if demand response were not available, the Company would likely
choose to build a 170 MW simple-cycle combustion turbine ('SCCT'). The participants
agreed to use the value of this 170 MW SCCT "multiplied by the effective load carrying
capacity, measured over twenty years, plus the corresponding deferred energy savings"
as the minimum avoided cost of DR. Settlement Agreement, p. 4. This value is to be
used "even in years when the IRP shows no peak-hour capacity deficit" and "will be
updated with each IRP based on changes that include, but are not limited to need,
capital cost, or financial assumptions." Settlement Agreement, pp. 4-5.
The value of DR does not equate to the amount of DR capacity the Company is
required to accept and may acquire. The participants agreed that:
The Company must Use existing demand response
resources when possible. This includes using, to the extent
possible, current demand response equipment owned or
available to ldaho Power and participating demand response
customers, which currently represents approximately 400
megawatts of potential demand response capacity.
Settlement Agreement, p. 3 (emphasis added). As described in Staff's Comments in
Case No. IPC-E-13-14, the "resource-based value calculation combined with cost
savings and program modification helps the Settlement preserue previous investments
in a valuable DR resource while limiting cosfs in years when it is not needed to meet
load." Staff DR Comments, p. 7 (emphasis added). As Staff correctly pointed out, the
value calculation was intended to allow the Company to incur program costs even when
such costs were not justified by the lRP. The value calculation was not intended to
create a limit on participation or capacity.
IDAHO POWER COMPANY'S REPLY COMMENTS - 5
Within each program description in the Settlement Agreement, the parties
described how existing, and in some cases new, participants would be included in the
programs going forward. The parties agreed early on that participation should not be
unnecessarily limited and that the Company would utilize its "participating demand
response customers." Settlement Agreement, p. 3. For the A/C Cool Credit program,
the parties agreed that existing participants will be allowed to remain in the program,
new participants will be allowed to join, and, in certain limited circumstances, the
Company will contact customers to inquire about participation. Settlement Agreement,
p. 5. For the Irrigation Peak Rewards program, participants are limited to past program
participants with an active, working load control device. Settlement Agreement, p. 6.
For the FlexPeak Management program, Idaho Power will not actively seek to expand
the capacity. Settlement Agreement, p. 7. In no case does the Settlement Agreement
allow Idaho Power to turn away existing program participants. ln no event does the
Settlement Agreement intend or imply a limitation of DR capacity based upon the 170
MW SCCT used to calculate the value of DR programs.
Because participation is not limited and because the Company must use existing
DR resources when possible, the Company is required to accept up to 2012
participation levels, which is approximately 440 MW of DR. Staff alleges that attrition
will substantially reduce the program sizes and capacity that the Company may receive.
ldaho Power also believes that some unknown level of attrition will likely occur for each
program. However, under the terms of the Settlement Agreement, ldaho Power must
accept up to 440 MW of DR capacity if program participants choose to participate or any
IDAHO POWER COMPANY'S REPLY COMMENTS - 6
new A/C Cool Credit participants wish to sign up at the programs' current incentive
amounts.
B. Staffs Assumption Limitins DR Gapacitv to Onlv 170 MW ls Not Consistent
with ldaho Power's 2013lRP.
It is reasonable to include DR in the amounts identified in the Settlement
Agreement and analyzed in the 2013 IRP for the Company's capacity deficiency
determination foravoided cost rates. The Company's 2013 IRP utilizes DR up to 400
MW to meet all identified capacity deficits up to July 2021. As stated above, the
Settlement Agreement requires the Company to accept a!! DR up to 2012 levels.
Historical DR peak reduction capacity levels reported in the 2013 IRP are 336 MW for
2010, 403 MW for 2011, and 438 MW for 2012. 2013 lRP, p. 40. The preferred
resource portfolio from the 2013 lRP relies primarily upon the Boardman to Hemingway
(.B2H') transmission line with associated market purchases as the major resource
acquisition to cost-effectively meet the Company's service obligations. 2013lRP, p. 8.
The preferred resource portfolio assumes an expected operationa! date of B2H as 2018.
td.
Because of delays in the ongoing required state and federal permitting processes
for the B2H line, the Company recently announced that the operational date for B2H will
be no sooner than 2020. Attachment t hereto contains the updated load and resource
balance that was the basis for Table 3 in Idaho Power's Application in this proceeding
and shows the inclusion of 440 MW of DR, which eliminates summer deficits through
July 2020. The amount of DR begins at 30 MW in the summer of 2014 and gradually
increases to 440 MW in the summer of 2021, which is the first summer the DR
programs are not able to eliminate the entire deficit; i.e., the first deficit year. Just as
IDAHO POWER COMPANY'S REPLY COMMENTS - 7
the preferred resource portfolio relied upon contributions from DR to meet peak capacity
deficiencies prior to B2H becoming operational, the first resource portfolio that
considers resource options without the addition of B2H meets all near-term, peak-hour
capacity deficiencies with DR, up to 400 MW. See 2013 lRP, p. 91, Resource Portfolio
3. Resource Portfolio 3 considers the Company's resource portfolio without the addition
of the B2H line, and includes DR up to 400 MW. This resource portfolio meets all
identified capacity deficits to July 2021 . lf DR were limited to the 170 MW suggested by
Staff, resulting in a first deficit year of 2016, the Company would have to presently be
developing the next combined- or simple-cycle combustion turbine in order to have it
operational to meet the 2016 deficit. However, the Company's IRP considered the
alternative that B2H would not be on-line when anticipated and, in those alternatives,
the Company's IRP calls for meeting those deficiencies with DR. ldaho Power's
customers have borne the costs associated with developing the Company's DR
programs and to ignore the past proven capabilities of these programs would be
incorrect.
Staff, without analysis or basis, determines that ldaho Power's DR programs will
shrink from approximately 440 MW to 170 MW as a result of the reduced incentives
agreed upon in the Settlement Agreement. Staff Comments, p. 6. A reduction in the
amount of DR was anticipated in the Settlement Agreement due to a current lack of
need for the amount of DR that had been attained in the past. Although the Company
has not projected what level of attrition will occur, the Company believes Staff is
overestimating the amount of expected attrition for all three demand response
programs. Even with some level of attrition, because the capacity deficiencies start at
IDAHO POWER COMPANY'S REPLY COMMENTS - 8
approximately 30 MW and gradually ramp up past 440 MW in 2021, some level of
attrition from the 438 MW acquired from DR in 2012, will still enable the deficits to be
met, and for the DR programs to ramp up over time accordingly. lt is entirely
reasonable to assume that DR will be acquired at levels up to those achieved in prior
years, and a chance that participation may grow. The Settlement Agreement requires
ldaho Power to accept levels up to those of past years and also requires ldaho Power to
accept new participants in the A/C Cool Credit program. As customer load continues to
grow and the need for increasing amount of DR returns, the Company anticipates
incentive payments may need to be adjusted to attain program participation levels
experienced in the past. This was contemplated in the DR workshops and Settlement
Agreement and demonstrates the flexibility the DR programs are able to provide.
Staff alleges that capacity of the lrrigation Peak Rewards program participation
will fall from 320 MW to 110 MW. Staff provides no analysis to support this claim and
fails to consider that the irrigation customers were represented and agreed to the
incentive levels set out in the Settlement Agreement. Staff alleges that the irrigators
repeatedly voiced concerns about the incentive reduction in the DR workshops. ldaho
Power acknowledges that the irrigators were concerned about a reduction in the
program incentive. However, after such concerns were voiced, the irrigators, ldaho
Power, Staff, and others reached agreement on appropriate incentive amounts as
evidenced by their support of the Settlement Agreement. After signing, no such
representations were made.
While Staff acknowledges that the exact capacity of ldaho Power's DR programs
is unknown, it continues to assert that the Company will experience a reduction in
IDAHO POWER COMPANY'S REPLY COMMENTS.9
capacity from 440 MW to 170 MW, shrinking to 39 percent of the programs' former size.
ldaho Power believes that the terms set forth in the Settlement Agreement that maintain
customer participation and infrastructure, and which relied upon agreement from
representatives of customers will prevent such a drastic decrease in the size of its DR
capacity.
Furthermore, the Settlement Agreement provides flexibility to the Company in
years where the lRP demonstrates a need for increased demand response capacity.
The Company must "reevaluate the value calculation as the IRP changes." Settlement
Agreement, p. 3. The Commission acknowledged this flexibility in its order approving
the Settlement Agreement, encouraging the Company to "continue evaluating
opportunities associated with DR programs on an ongoing basis." Order No. 32923, p.
7.
Staff was highly critical of ldaho Power's responses to discovery questions posed
by Staff in this matter stating, "ln multiple responses, ldaho Power emphasized that the
'Company believes that is a reasonable assumption that it can satisfy the deficit of 30
Megawatts ("MW") in 2014 with its existing demand response programs if
necessary."' Staff Comments, p. 6. Staff further states that it "does not believe that
satisfying a deficit of 30 MW in the first year of a 2O-year planning period is sufficient
evidence to justify including 440 MW of demand response in each year of the planning
period." /d. ldaho Power's answers to discovery questions quoted by Staff above were
in direct response to Staff questions that asked about the level of DR the Company
expected to acquire for 2014. ldaho Power was answering the question asked in
reference to the reasonable assumption that it can satisfy the 30 MW deficit in 2014 with
IDAHO POWER COMPANY'S REPLY COMMENTS - 1O
existing DR. However, just as it is reasonable to expect that a 30 MW deficit in 2014
will be met by existing DR, it is reasonable to expect that the increasing deficits through
2021 will be met by the existing DR of up to 440 MW, which is what ldaho Power is
required to accept pursuant to the Settlement Agreement. An alternative resource
portfolio that meets all capacity deficits through 2021 with up to 400 MW of DR was
analyzed and included in the Company's acknowledged 2013 lRP. ln this case, the
Company provided updated 2013 IRP identified capacity deficits with the approved
update to the load and natura! gas forecasts, as well as updated contracts for use in the
avoided cost rate methodologies-and included the additional 440 MW of DR as
provided by the Settlement Agreement and as analyzed in the Company's accepted
2013 IRP. Staffs arbitrary limitation of DR to 170 MW is not reasonable or supported
by the IRP and Settlement Agreement.
III. CONCLUSION
Idaho Power respectfully requests that the Commission issue an order approving
the capacity deficiency period shown in Table 3 of ldaho Power's Application, with a first
deficit occurring in July 2021. As discussed above, Staffs assumption limiting DR
capacity to only 170 MW is not supported by the Settlement Agreement, or any other
analysis. ldaho Power's inclusion of up to 440 MW of DR is consistent with the
Settlement Agreement's requirement that ldaho Power accept al! existing, and some
new, demand response participants up to 2012levels (which was 438 MW). lt is also
consistent with the preferred and alternative resource portfolios in the 2013 IRP, which
utilizes DR to meet all identified capacity deficiencies until the B2H transmission line
can be completed.
IDAHO POWER COMPANY'S REPLY COMMENTS - 11
The purpose of this docket is to establish, outside of the lRP, the capacity
deficiency utilized for avoided cost PURPA pricing. With this purpose in mind, any
PURPA contracts entered into wil! lock in this capacity deficiency into its avoided cost
rates for the next 20 years, and cannot subsequently be changed. The effect of
arbitrarily limiting DR to 170 MW is to increase the avoided cost of capacity payments
made in any PURPA contracts, and to lock that higher payment in for the next 20 years
with no ability to change it, resulting in customers paying more than they should for
these contracts. Even if the next IRP analysis, or the continued operation of the DR
programs, shows that all capacity deficits are met through 2021 or beyond, the PURPA
contracts will have locked in capacity payments for 20 years based upon the limitation
of 170 MW of DR and a resulting capacity deficit that occurs at least five years sooner
than the reasonable analysis and requirements of the Settlement Agreement and 2013
IRP indicate. ldaho Power respectfully requests that the Commission issue an order
approving the capacity deficiency period shown in Table 3 of ldaho Power's Application,
with a first deficit occurring in July 2021.
Respectfully submitted this 14th day March 2014.
DONOVAN E. WALKER
Attorney for ldaho Power Company
IDAHO POWER COMPANY'S REPLY COMMENTS - 12
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 14th day of March 2014 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
Kristine A. Sasser
Deputy Attomey General
ldaho Public Utilities Commission
47 2 W est Washington (83702)
P.O. Box 83720
Boise, ldaho 83720-007 4
J. R. Simplot Company
Peter J. Richardson
Gregory M. Adams
R]CHARDSON ADAMS, PLLC
515 North 27th Street
Boise, ldaho 83702
Dr. Don Reading
6070 Hill Road
Boise, ldaho 83703
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Christa Bearry, Legal Assistant
IDAHO POWER COMPANY'S REPLY COMMENTS - 13
BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
GASE NO. IPG-E-13-21
IDAHO POWER GOMPANY
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