20140423Comments.pdf

WELDON B. STUTZMAN
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 3283
Street Address for Express Mail:
472W WASHINGTON
BOrSE ID 83702-5918
Attorney for the Commission Staff
IN THE MATTER OF THE APPLICATION OF
IDAHO POWER COMPANY FOR APPROVAL
OF ITS AGREEMENT WITH ENERNOC,INC.
TO IMPLEMENT AND OPERATE A
VOLUNTARY COMMERCIAL DEMAND
RESPONSE PROGRAM
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
CASE NO.IPC-E-14.02
COMMENTS OF THE
COMMISSION STAFF
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 Application and Notice of Modified Procedure issued in Order No. 33007 on April 2,
2014, submits the following comments.
BACKGROUND
On March 7,2|I4,Idaho Power Company filed a Petition requesting approval of the
third amendment to the Company's Agreement with EnerNOC, Inc. EnerNOC pursuant to the
Agreement provides a demand response program for Idaho Power's commercial and industrial
customers, identified as its Flex Peak Management Program. The objective of the Flex Peak
Program is to reduce demand on Idaho Power's system during peak load times through
customers' voluntary reduction in electrical use. EnerNOC is responsible for developing and
STAFF COMMENTS APRIL 23,2014
implementing all marketing plans, securing participants, installing and maintaining all equipment
beyond Idaho Power's meter necessary to reduce demand, track participation, and report results
to the Company. Petition, p. 2.
The Commission approved the initial Agreement between Idaho Power and EnerNOC in
May 2009, and approved the first amendment to the Agreement in June 2010. In March 2013,
the Company filed a petition seeking Commission approval of a second amendment to the
Agreement allowing the Company and EnerNOC to reduce the amount of weekly nominated
demand reduction obligations, the available hours of the program, and the amount per kilowatt
that Idaho Power pays to EnerNOC. The Company filed a Petition in this case seeking approval
of the third amendment that modifies the Agreement to comply with the terms of the settlement
approved by the Commission in October 2013. Order No. 32923.
STAFF REVIEW
Staff has review the Company's petition and supports its proposal to extend its
arrangement with EnerNOC. Idaho Power's five-year contract with EnerNOC terminated
February 2014 and the current proposal extends the contract to the end of the 2014 season. The
proposal reduces payments to EnerNOC, aligns the contract to comply with the demand response
(DR) Settlement, along with additional changes. Staff believes the amendment comports with
the DR Settlement approved by Commission Order No. 32923 and is in the best interest of
customers for the 2014 season.
Due to the contract modifications, the Company forecasts a reduction in annual
expenditures from $2.7 million in 2013 to approximately (This section of Staff s comments
contains confidential information subject to protective agreement.) in 2014. To facilitate the
lower annual cost, the amendment reduces EnerNOC's weekly committed load reductions from
its 2013 commitment levels. The Company asserts the change was necessary to reduce the
amount EnerNOC charges Idaho Power, but anticipates weekly nominations and actual load
reductions will be similar to 2013 results.
The contract also changes the operating parameters following the third mandatory event.
Specifically, FlexPeak is subject to additional dispatch only if (This section of Staff s
comments contains confidential information subject to protective agreement.)
Staff does not believe the modification will harm
the viability of the program, nor unduly burden FlexPeak participants. While the operating
STAFF COMMENTS APRIL 23,2014
parameter was not discussed in the DR Settlement negotiations, it was brought to the attention of
the Company's Energy Efficiency Advisory Group (EEAG) as a (This section of Staffs
comments contains confidential information subject to protective agreement.)
STAFF' RECOMMENDATIONS
Staff recommends the Commission approve the Third Amendment between Idaho Power
and EnerNOC.
Respecttully submiffed this *J day of Apr il20l4.
Weldon B. Stutzman
Deputy Attomey General
Technical Staff: Nikki Karpavich
i :umisc:commentVipce l4.2wsnk comments
STAFF COMMENTS APRIL 23,2014
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 23'd DAY OF APRIL 2014,
SERVED THE FOREGOING NON.CONFIDENTIAL COMMENTS OF THE
COMMISSION STAFF IN CASE NO. IPC-E-74-02, BY MAILING A COPY
THEREOF, POSTAGE PREPAID, TO THE FOLLOWNG:
JULIA HILTON
REGULATORY DOCKETS
IDAHO POWER COMPANY
PO BOX 70
BOISE ID 83707-0070
E-MAIL: [e-mail]
[e-mail]
C Bearry@idahopower. com
(Confidential Copy)
PETER J RICHARDSON
GREGORY M ADAMS
RICHARDSON ADAMS PLLC
515 N 27TH STREET
BOISE TD 83702
E-MAIL : oeter(Erichardsonadams.com
gre [e-mail]
(Confidential Copy)
BENJAMIN J OTTO
ID CONSERVATION LEAGUE
7IO N 6TH STREET
BOISE ID 83702
E-MAIL: [e-mail]
(Confidential Copy)
TAMI WHITE
IDAHO POWER COMPANY
PO BOX 70
BOISE ID 83707-0070
E-MAIL: [e-mail]
Qrlon-Confi dential Copy)
DR DON READING
6070 HILL ROAD
BOISE ID 83703
E-MAIL: [e-mail]
(Confidential Copy)
CERTIFICATE OF SERVICE