20140423Comments.pdf

Benjamin l. Otto (ISB No. 8292)
710N6'hStreet ,'i:: ;.; i?.i ',i -i: ir
Boise,ID 83701
Ph: [phone] x12
Fax [phone]
[e-mail]
Attorney for the Idaho Conservation League
BEFORE THE IDAHO PUBLIC UTITITIES COMMISSION
IN THE MATTER OF IDAHO POWER
COMPAI.IY'S APPLICATION FOR
APPROVAL OF ITS AGREEMENT
WITH ENERNOC,INC., TO
IMPLEMENT AND OPERATE A
VOLUNTARY COMMERCIAL
DEMAND RESPONSE PROGRAM
CASENO. IPC-E-14-02
IDAHO CONSERVATION LEAGUE
COMMENTS
The Idaho Conservation League (ICL) supports the Third Amendment to the contract
between EnerNOC and Idaho Power regarding the FlexPeak program. Idaho Power's 2013
Demand Side Management Annual Report shows a benefit to cost ratio of 1.43 for the FlexPeak
program.' The proposed amendments include a minor reduction in both the size and cost of the
program and therefore are likely to maintain this cost-effectiveness. After reviewing the
application and discovery in this case, ICL urges the Commission to approve the contract, which
enables the continuation of a robust, cost-effective demand response program and thereby is in
the public interest.
Demand response programs can benefit ratepayers by deferring or avoiding the cost of
both operating existing and building new supply-side resources. Like most things, the devil is in
the details. Here the relevant details are the characteristics and the cost of the demand response
resource. The characteristics of the program define the size and availability, which combined
indicate the ability of the program to defer or avoid supply-side resources. The cost of the
' Idaho Power 2013 DSM Annual Report at97.The Commission may take official notice of this periodic report
filed by a regulated utility in case no IPC-E-14-04. IDAPA 31.01.01.263.01.c.
IPC-E-14-02
ICL COMMENTS 1 April23,20l4
program indicates whether operating demand response is less expensive than supply-side
resources. Ratepayers benefit when both the characteristics and the cost of demand response can
cost-effectively avoid supply-side resources.
The amended contract between EnerNOC and Idaho Power improves both the
characteristics and the costs of the already successful, cost-effective FlexPeak program. In terms
of characteristics, the Third Amendment reduces the size of the resource to between 30 - 35 MW
of capacity.'This is a minor change from the assumed demand reduction in the cost-effectiveness
tests of 40 MW.3 The Third Amendment does make some important changes to other
characteristics of the program. First, it changes the available dates to Iune 15 through August 15
in order to align this program with the Idaho Power's other demand response programs.n ICL
supports this change because during the demand response workshops that occurred in case IPC-
E-13-14 Idaho Power dispatchers requested clarity on when to dispatch demand response
programs. Aligning the available time periods for all three programs increases clarity by reducing
the variables a dispatcher must consider. Similarly, the Third Amendment changes the
notification timing requirements and methodology between EnerNOC and Idaho Power for
dispatching the FlexPeak programs.t Improved notification also assists dispatchers and should
lead to increased use of demand response programs. Ratepayers benefit from the use of cost-
effective programs.
Another critical change to the program is the creation of a "trigger" limiting the dispatch
of the FlexPeak program beyond three mandatory events. As a member of the Energy Efficienry
Advisory Group (EEAG) ICL understands the details of this trigger and the motivations for this
contract provision. Due to the confidential nature of the details, ICL will not discuss them in
2 This is the non-confidential answer to Staffproduction Request No 2. The precise number is on the first page of
Attachment I to Idaho Power's Application in this case.
3 See ldaho Power 2013 DSM Annual Report at Supplement l, p 13.
a Application at 5.
5 See Page 2 of Attachment 2 to ldaho Power's Application.
IPC-E-t4-02
ICL COMMENTS April23,2014
these comments.t ICL supports the trigger for two reasons. First, it provides clarity for
dispatchers regarding when to use the demand response programs given the limited hours and
days they are available to meet energy demands. Second, the trigger strikes an appropriate
balance between constraining and providing flexibility for ldaho Power to dispatch the program.
The Third Amendment provides more flexibility than the trigger initially described to the EEAG
on February 6,2014.
The Third Amendment improves the characteristics of the FlexPeak program by
maintaining sufficient size and providing clarity to dispatchers, which should facilitate more use
of the program. Also, based on Idaho Power's confidential discovery responses the cost in 2014
will be lower than prior years. Increased use of the program at a lower cost serves ratepayers and
the public interest. Finally, after reviewing the application and discovery in this case ICL believes
the Third Amendment aligns with the demand response stipulation approved by the Commission
in IPC-E-13-14. For these reasons ICL urges the Commission to approve the Third Amendment.
DATED this 23 day of April,z}I4,
Benjamin I. Otto
Idaho Conservation League
6 Recital 6 on page 2 of Attachment I to Idaho Power's Application describes the trigger in detail. Page 2 of
Attachment 2 to Idaho Power's Application further describes the implications of this trigger.
rPC-E-t4-02
ICL COMMENTS
Respeltfully submitted,
April23,20T4
CERTIFICATE OF SERVICE
I hereby certifr that on this 23rd day of April,20l4,I delivered true and correct copies of
the foregoing COMMENTS OF THE IDAHO CONSERVATION LEAGUE to the following
persons via the method of service noted:
Hand delivery:
Iean Iewell
Commission Secretary (Original and seven
Idaho Public Utilities Commission
427 W. Washington St.
Boise,lD 83702-5983
Electronic Mail:
Idaho Power
Julia A. Hilton
Tami White
Regulatory Dockets
Idaho Power Company
P.O. Box 70
Boise,Idaho 83707
j hilton@idahopower. com
[e-mail]
dockets @idahopower. com
ICIP
Peter J. Richardson
Gregory M. Adams
Richardson & O'Leary, PLLC
515 N. 27th Street
Boise, lD 83702
peter@richardsonandoleary. com
gre g@richardsonandoleary. com
Dr. Don Reading
6070 Hill Road
Boise,Idaho 83703
dreading@mindspring. com
copies provided)
Benjamin I. Otto
IPC-E-14-02
ICL COMMENTS 4 Apnl23,2014