20190524Patteson Direct.pdf

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I
RE C E IVED
l0t9lt,qT 2b Pl{ lr: l*5
iTil,?ffic#*fnh18t,o*
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION
OF ]DAHO POWER COMPANY EOR
AUTHOR]TY TO MODIFY SCHEDULE 15,
DUSK TO DAWN CUSTOMER LIGHTING,
AND SCHEDULE 41, STREET LIGHTING
SERVICE, TO ALLOW FOR LIGHT-
EM]TTING DIODE TECHNOLOGY.
CASE NO. ]PC-E_79_77
IDAHO POWER COMPANY
DIRECT TESTIMONY
OF
KRISTY M. PATTESON
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n Pl-ease state your name, business address, and
present position
"Company").
with Idaho Power Company ("Idaho Power" or
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A. My name is Kristy M. Patteson. My business
address is 7227 West Idaho Street, Boise, Idaho 83702. I
am employed by Idaho Power as a Regulatory Analyst II.
0. Please describe your educational background.
A. In May of L992, I earned a Bachel-or of Science
degree in Mathematics from Boise State Unlversity. I have
al-so attended electric utility ratemaking courses,
including "The Basics: Practical Regulatory Tralning for
the Efectric Industryr " a course offered through New Mexico
State University's Center for Pubfic Utilities,
"Residential Demand Charges" presented by Electric
Utllities Consultants, Inc., and Edison Electric
Institute's "El-ectric Rates Advanced Course."
O. Please describe your work experience with
Idaho Power.
A. I began my employment with Idaho Power in 7992
in Corporate Services where I provided technical- support to
Company employees needing assistance with Microsoft Office
products. In 1999, I began working in the Metering
Department where I was responsible for the operation and
maintenance of Idaho Power's handhe1d meter reading system.
In 2006, I began working in the Load Research and
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PATTESON, DI 1
Idaho Power Company
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1 Forecasting Department where I was responsibJ-e for
2 conducting analyses and studies with an emphasis on the
3 study of energy use, behavior, and demand characteristics
4 of specific groups and cl-asses of customers in Idaho
5 Power's servi-ce area.
6 Durj-ng the fall of 20L5, L accepted my current
7 posltion as a Regulatory Analyst in the Regulatory Affairs
8 Department. As a Regulatory Analyst, I support the
9 Company's various regulatory activities, including tariff
10 administration, regulatory ratemaking and compl-j-ance
11 filings, and the development of various pricing strategies
12 and policj-es.
13 O. What is Idaho Power proposing in this docket?
14 A. Idaho Power is requesting approval to (1)
15 modj-fy Schedule 15, Dusk to Dawn Customer Lighting
16 ("Schedul-e 15" or "area lighting") and Schedule 4L, Street
11 Lighting Service ("Schedule 41" or "street lighting") to
18 al-low for light-emitting diode ("LED") technofogy effective
19 October t, 2019, and (2) cl-ose Option \\B" of Schedule 47,
20 customer-owned, Idaho Power-maintained systems effective
2L September 30, 2023.
22 O. Is the Company requestlng a rate change as
23 part of this filing?
24 A. No.
25 0. How is your testimony organized?
PATTESON, DI 2
Idaho Power Company
1 A. My testimony wiII begin with (1) an overview
2 of Idaho Power's current area lighting and street lighting
3 service offerings followed by (2) an explanation of why
4 Idaho Power is planning to instal-l- LED light fixtures for
5 all Company-owned area and street lighting systems. I will
6 then (3) explain the Company's plan to replace al-l- Company-
7 owned lighting systems with LED light fixtures and
B discontinue maintenance of customer-owned lighting systems,
9 (4) provide the revenue requirement impact analysis, and
10 (5) describe the proposed changes to Schedules 15 and 47.
11 Finally, I wiII (6) describe the Company's plan to
L2 communicate with customers who will be impacted by this
13 change.
74 I. IDAIIO POIYER'S CI'RRENT ARE.A ATiID STREET LIGHTING SERVICES
15 O Pl-ease describe the area lighting and street
to Idaho Power76 Iighting services currently available
L] customers.
Idaho Power's lighting servicesA1B
19 through two tariff schedules: Schedul-e 15 and
to electric
are provided
Schedule 4L.
service20
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Schedule
the
15 is applj-cabJ-e
outdoor dusk to dawn Iighting ofprovided for
commercial,
yards, driveways,
under Schedule 15
industrial, and residential- customer
Customers taking
a per lamp basis
and premises.
are charged on
grounds,
service
for the
PATTESON, DI 3
Idaho Power Company
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type and wattage of lamp. A11 light fixtures under
Schedule 15 are owned and maintained by the Company.
Schedule 4L is appllcable to electric service
provided for lighting of public streets, public a1leys,
public grounds, and thoroughfares to improve visibility for
drivers, ds well as to illuminate outdoor pedestrj-an
walkways. Schedul-e 4L provides three service options for
street lighting customers.
. Optlon \\A" ("Schedule 4tA" ) provides for Idaho
Power-owned and Idaho Power-maintained street
lighting systems. Street lighting systems under
this option are not metered and customers pay
monthly lamp charges based on their choice of
standard wattage high pressure sodium vapor lamps.
. Option \\B" ("Schedule ALB" ) provides for customer-
owned, fdaho Power-maintained street lighting
systems. Option \\B'l was cl-osed to new service in
2072 as a part of Idaho Power's l-ast general rate
case.l AIl new customer-owned lighting systems
instal-l-ed after January L, 2072, are required to
take service under Option C, where the lighting
system is owned, operated, and maintained by the
customer.
Option
option
a \\c//
for
("ScheduIe 4LC") provides
customers choosj-ng to own
a service
their lighting
1 Case No. IPC-E-11-08, Order No. 32426.
PATTESON, DI 4
Idaho Power Company
1 system. Option \\C" allows customers with non-
2 metered lighting systems to provide their own
3 maintenance without being charged for Idaho Power-
4 provided maintenance. Option \\C" al-so provides
5 greater flexibil-ity to customers as they are not
6 limited to the liqht fixture offered by Idaho Power;
1 rather, the customer can install llghting systems
B not offered by the Company.
9 Q. How many customers take service under
10 Schedul-es 15 and 47?
11 A. Table 1 summarizes the customer counts for
L2 each of the three service options for Schedule 4L and for
13 Schedule 15.
14 Tab].e 1: Customer Counts
Service
Option Description #of
Customers
41A Company-Owned / Company-Maintained B2
4 18*Customer-Owned / Company-Maintained*42
4LC Customer-Owned / Customer-Maintained 531
Dusk to Dawn Llghting 6,389
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*No New Service as of January 2012
II. FACTORS DRIVING LED CON\ZERSION
O. Generally, what factors are drivlng the
Company's request for an LED conversion?
A. The Company is proposing to transition away
from the existing high pressure sodium and metal halide
liqht technology, collectively referred to as High
PATTESON, DI 5
Idaho Power Company
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1 Intensity Discharge ("HID") toward LED Iighting in
2 recognition of several- factors. First, HID tighting
3 technology is expected to reach a point of technical
4 obsolescence in the coming years. Second, technological
5 advances and improving economics are making LED lighting
6 options more cost competitive as compared to HID
7 technologies. Lastly, LED lights use l-ess energy, operate
8 with lower maintenance costs, and provide improved Iighting
9 quality. When all of these factors are considered in
10 aggregate, the Company believes its adoption of LED
11 lighting options will serve the best. interests of its
L2 customers.
13 A. HID Lighting Techno1 Will Become Obsolete
74 O. What type of lighting technology does the
15 Company currently own and install for Schedules 15 and 4L?
76 A. A11 Company-owned lighting systems instal-l-ed
77 under Schedul-es 15 and 4l currently consist of HID light
18 fixtures.
19 O. Why is Idaho Power proposing to move away from
20 the HID technology?
27 A. Due to changing technology within the lighting
22 industry, the Company has less certainty regarding the
23 future availability of HID lighting. Idaho Power's current
24 fixture manufacturer has recently notified Idaho Power that
25 it has discontinued a}l but two of the high pressure sodium
PATTESON, DI 6
Idaho Power Company
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fixtures and has eliminated metaf hal-ide optlons on many
other fixtures. Based on conversations with this and other
manufacturers, the industry trend is to manufacture more
LED liqht fixtures and fewer HID light fixtures. The
Company expects HID street liqht and area light options to
become increasingfy obsolete as LED replacements become
more widely util-ized.
B. Industry Lighting Trends
O. What trends has the industry experienced with
regard to area lighting and street lighting installations?
A. According to a 2017 report by Navigant
Consulting (*2071 Report on LED Adoption"),2 LED penetration
in area and street lighting applications j-n the U.S. has
grown from 0.3 percent in 2070 to an estlmated 28.3 percent
in 2016, while parking lot applications have grown from 1
percent in 2070 to an estimated 26.2 percent in 20L6.
O. What changes have occurred with LED technology
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79 effective option for Idaho Power's street
20 services?
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Iights a cost-
I ight 1ng
2 Navigant Consulting, Adoption of Light-Emitting Diod.es in
Common Lighting Applications, Sol-id-State Lightlng Program Building
Technologies Office Energy Efficiency and Renewabl-e Energy U.S.
Department of Energy, pp. 51-54.
https : / /www. energy . govl s lte s / pr od / f rle s / 2071 / AA / fi 5 / Led-adopt ion-juI20l-7 0.pdf
PATTESON, DI 1
Idaho Power Company
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A.Reduced capital costs
lighting opti-ons. Accordi-ng
Adoption, the typical price
fixtures have decreased more than 50 percent from 20L2 to
201,6 and the typical price of an LED parking 1ot/area light
has decreased more than '15 percent from 2072 to 2016.3
O. Have other utilities undertaken a similar LED
replacement pro;ect of their own?
A. Yes. Several- utilities have already embarked
on their own projects to replace HID light fixtures with
LED liqht fixtures. Avista, Xcel Energy, Pacific Gas &
Electric, and Portland General Electric have replaced HTD
liqht fixtures with LED liqht flxtures to varying degrees,
ranging from replacement of all- lamp type and wattages to
only replacement of sel-ect lamp styles and wattages.
16 C. Benefits of LED ts
11 O. What attributes make LED technology a
preferred replacement for the existing HID technology?
A. LED lighting provides several advantages over
traditional HID lighting options: LED lights use less
energy, reduce maintenance costs, and provide better
lighting quality as compared to HID technology.
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PATTESON, DI 8
Idaho Power Company
to the
of LED
are creating parity in
207'l Report on LED
street and roadway Iight
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3 rd.
1 Q. How will the Company save energy by replacing
2 all Company-owned HID lighting systems with LED liqht
3 fixtures?
4 A. LED light fixtures are more energy efficient
5 than HID llghting systems because they use l-ess energy to
6 produce the same or better light quality.
1 Q. Did the Company quantify the estimated energy
B savings?
9 A. Whil-e energy savings varies depending on the
10 wattage and the type of fixture being replaced, Lf all
11 Schedul-e 15 and 4L Company-owned lighting systems are
L2 replaced with LED light fixtures, Idaho Power estimates an
13 annual reduction in energy consumption of approximately
74 8,581 megawatt-hours. Thls reduction in energy consumption
15 results in net power supply expense savings of
76 approximately $250,000 on a level-ized basis that wil-I
L1 automati-caIly flow back to customers through the Power Cost
18 Adjustment ("PCA") mechanism.
19 O. How will the replacement of all Company-owned
20 HID lighting systems with LED liqht fixtures resul-t in
2L reduced maintenance costs?
22 A. The operating life of an LED is longer than
23 that of an HID bul-b. The LED light fixtures specified for
24 the LED conversion project have an L70 rating of 100,000
25 hours per Illuminating Engineering Society standards. An
PATTESON, DI 9
Idaho Power Company
7 L10 rating specifies that the LED must maintain 10 percent
2 of its initial lumens during its rated life. Assuming an
3 Ll 0 rating of 100,000 hours and 4,059 burn hours annua11y,
4 the projected life of the specified LED light fixtures is
5 approximately 24.6 years (100,000 hours/4,059 hours per
6 year burn time) . By comparison, Idaho Power's most
7 commonly installed 100W high pressure sodium vapor bulb has
8 an expected l1fe of approximately 20,000 hours,a roughly 20
9 percent of the expected l-ife of an LED fixture.
10 O. How does the liqht quality of LED lights
11 compare to that of HID lighting?
72 A. LED lights provide better light quality. LED
13 Iights project light in a focused pattern, directing light
74 more precisely where it is needed. In addition, the color
15 temperature of the light appears whiter wlth better color
16 rendition thus providing greater clarity than the yellow
l1 hues of high pressure sodium vapor lighting. The result is
18 more uniform liqht coverage, with Iess glare and fewer dark
L9 spots, whi-ch improves visibil-ity due to better J-ighting
20 quality.
2t O. Has fdaho Power had any experience with
22 replacing area lights or street Iights with LED light
23 fixtures?
a The lamp life of HID lamps varies by lamp manufacturer, Iamp
orientation, and lamp wattage.
PATTESON, Dr 10
Idaho Power Company
18 A. Replacement of Company-Owned Lighting Systems
19 u Does the Company own all lighting systems
20 taking service under Schedule 15 and Schedule AtA?
27 Yes. AII lighting systems taklng service
22 under Schedule 15 and Schedule 41A are Company-owned.
5 Navigant Consulting, Enerqy Savings Estimates of Light Enitting
Diodes in Niche Lighting AppTications, Building Technologies Program Office
of Energy Efficiency and Renewable Energy U.S. Department of Energy, p. 1.
https://wwwT.eere.energy.gov,/buildings,/publications/pdfs/ss1/nlchefinalreportjqn"ery? ! r r.!q!
PATTESON, Dr 11
Idaho Power Company
1 A. Yes. In August 2073, Idaho Power repl-aced
2 existing high pressure sodium vapor light fixtures in a
3 Company-owned parking lot with LED llght fixtures. Idaho
4 Power found that the LED light fixtures provided better
5 lighting. Before and after photos of the parking l-ot are
6 provided in Exhibit No. 1.
1 Q. Are there benefits associated with the
8 installation of LED light fixtures other than better
9 lighting quality and reduced costs?
10 A. Yes. LED lighting fixtures can be recycled
11 whereas hiqh pressure sodium 1amps, which make up most of
12 Idaho Power's current street lighting systems, cannot be
13 recycled and require special handling for disposal.
74 According to a report prepared for the U.S. Department of
15 Energy, "LEDs contain no mercury and require no special
16 handling for disposal."s
Ll III. IDATIO POIYER' S REPI.ACE!,IENT PI,ATit
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O. Does the Company plan to replace al-l- existing
fixture types and wattages under Schedule 15 and Schedule
41A with LED liqhting fixtures?
A. Yes. The Company plans to replace all
fixtures under Schedule 15 and Schedule 4lA; this includes
a1l wattages for both high pressure sodium vapor and metal
halide lighting systems. The fixtures that are removed
from service wiII be retired using the Company's normal
retirement process.
O. If the Idaho Public Utll-ities Commission
("Commission") were to approve the Company's request, wilI
Idaho Power continue to instal-l- HID lighting systems for
Schedule 15 or Schedufe 4L?
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A . No. Upon Commission approval
Company-owned HID J-ighting systems
of the Company's
will no longer
7,76 be avail-able for new instalfations effective October
I1 20L9.
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O. When
the Company-owned
fixtures ?
does the Company plan to begin replacing
LED IightHID lighting systems with
. With Commission approval, the Company expects
replacing and retiring the Company-owned HID
systems in October 2079.
Who wiff perform the work to replace all
Iighting systems with LED light fixtures?
A
to begin
lighting
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PATTESON, Dr L2
Idaho Power Company
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A Idaho Power w11I
replace all- Company-owned HID
liqht fixtures. The Company
approximately 25 percent of
over a four-year period.
O. How many light
to replace under Schedu1e 15
utilize current staffing to
lighting systems with LED
anticipates replacing
the existlng fixtures per year
fixtures does Idaho Power plan
and Schedule 41A?
A Idaho Power plans to replace 9,874 Iight
fixtures under Schedule 15 and 1,6,998 light fj-xtures under
10 Schedule 41A. The counts by lamp type and wattage as of
11 March 2079 are provided in Exhibit No. 2.
I2 O.Please describe the LED light fixtures the
13 Company plans to install.
fdaho Power worked witht4
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identify replacement LED products
liqht f ixture of f erings. Tabl-e 2
lumen ranges identified as the LED
HID lamp wattages.
TabJ-e 2: LED Equivalent Offerings
Iists the wattage and
replacement for existing
PATTESON, Df 13
Idaho Power Company
for
its supplier to
its existing HID
LED Replacement
Schedule 15 Area Lighting Watts Lumens
100W High Pressure
200W Hiqh Pressure
400W High Pressure
Sodium
Sodium
Sodium
30-40w
70-85W
3,600-4,800
1 ,200-9,600
18, 000-24, 000175-200W
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LED Replacement
Schedufe 15 Flood Liqhtinq
200w High
400W High
400W Metal-Halide
HaIide1000W Metal-
Pressure Sodium
Pressure Sodium
70-85W
120-150w
120-150w
250-300W
Lumens
B, 100-10, 800
18,000-24,000
18,000-24,000
32,00 0-38, 000
Watts
Schedufe 41A Street Lighting
70W High Pressure Sodium
100W High Pressure Sodium
200W High Pressure Sodium
250W High Pressure Sodium
400W Hiqh Pressure Sodium
Lumens
3, 600-4, B0o
3, 600-4, 800
1 ,200-9,600
10, 000-14, 400
18,000-24,000
LED Replacement
Watts
30-40W
30-40W
70-B5W
115-140W
175-200W
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O. why
watts and lumens
single value?
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efficiency of LED
a range al-l-ows for
constantly improving and listlng
variances in input watts and
In addition, a necessary
may have
for a
does Idaho Power list a range for both
for the LED replacements rather than a
LED lighting is an evolving technology. The
light is
slight
time.lumens output
as different
range rs
fixtures
over
manufacturers of LED liqht
10 slightly different input
similar application.
watts and lumens output
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12 O. What design criteria was specified by Idaho
13 Power for the LED replacements?
PATTESON, Df 74
fdaho Power Company
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n Idaho Power specified the design criteria in
the areas of dark-sky
Dark-sky CompJ.iance
compliance and color temperature.
O. Why did Idaho Power's design criteria inc1ude
a speciflcatlon for dark-sky compliance?
A. Numerous cities in Idaho Power's service area
have committed to reducing light pollution; portions of
B1aine, Elmore, Custer, and Boise counties are part of the
Central- Idaho Dark Sky Reserve. Participating cities
require outdoor lighting fixtures that are "dark sky
friendly, " meaning that they minimize glare while reducing
light trespass and skyglow. All fixtures certified by the
fnternatj-onal Dark-Sky Association are required to be fulIy
shielded to face downward to the ground and minimize the
amount of blue light in the nighttime environment. Idaho
Power specified that all LED street light fixtures for
Schedule 41A be a full- cut-off design and all area light
fixtures for Schedule l-5 be ful-l- cut-off compliant in dark-
sky areas with the refractor removed from the fixture.
Due to the general nature of a flood liqht, the
2l flood light fixtures specified for Schedule 15 are not
22 dark-sky compliant.
23 Color TerpelelqEe
24 What is the significance of color temperature?
PATTESON, Dr 15
Idaho Power Company
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1 A. Col-or temperature describes the light
2 appearance provided by a light source. It is measured in
3 Kelvin ("K") on a scal-e from 1,000 to 10,000 ranging from
4 "warm white" to "cool- white" and then to "daylight". At
5 31 000K, the light produced is cal-led "warm white" and can
6 be described as yellow-white in appearance. Col-or
7 temperatures above 3,100K will emit a more neutral white
8 light and may even have a slightly bl-ue tint approaching
9 4,000K.
10 O. Did Idaho Power's design criteria include a
11 specification for color temperature?
72 A. Yes. Idaho Power specified 3,000K for all- LED
13 street Iight
Schedule 15,
fixtures for Schedule 41A. SimilarIy, for
t4 Idaho Power specified 3,000K for all area
15 light fixtures;however, Idaho Power specified 4,000K for
fixtures.L6 all- flood light
L] O. why did
18 temperature of 4,000K
19 A. To best
20 the existing Schedule
2L specified 4,000K for
ZZ existing flood
that currently
light
Idaho Power specify a different color
for fl-ood light fixtures?
align the type of liqht produced by
15 flood lights, Idaho Power
the LED replacement. Many of the
fixtures utilize metal- halide lamps
operate at approximately 4,000K.
PATTESON, Dr 76
ldaho Power Company
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B. Discontinue I'Iaintenance of Customer-Owned Fixtures
O. Pl-ease explain Idaho Powerf s request to
discontinue maintenance of customer-owned street tight
fixtures and to cl-ose service under Option \\B" of Schedul-e
41.
A. Idaho Power currently performs maintenance on
approximately 9,'742 fixtures owned by roughly 42 customers
in Idaho under Option \\B" of Schedul-e 41. As previously
mentioned, Option \\B" of Schedu1e 4l was cl-osed to new
service in 20L2 after which time all- new customer-owned
systems were required to take service under Option \\C'l of
Schedul-e 41, where the customer would own, operate, and
Ultimately, over time, the Companyanticipates that Option C will become theprimary service option for customer-ownedstreet lightlng systems as it transitionsto requirlng meters and customer-provided
maintenance on all new customer-ownedlighting systems.6
O. Why is now the
begin transitioning customers
right time for ldaho Power to
away from Option \\B//?
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13 maintain their own fixture. fn Case No. IPC-E-11-08, the
14 Company explained that
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26 fixtures to either Option \\
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customer-owned street liqht
properlyA" or Optlon \\C// wiII
6 Case No. IPC-E-11-08, Sparks DI, p. 2f, ll. 16-20.
PATTESON, DT T1
Idaho Power Company
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sj-tuate the Company for the impending obsolescence of HID
Iighting.
O. Are there other efficiencies to be gained by
moving away from maintaining customer-owned HID street
light fixtures?
A. Yes. If the Commission were to grant Idaho
Power's request to replace all Company-owned lighting
systems under Schedule 15 and Schedul-e 41A with LED liqht
flxtures, the new LED light fixtures would no longer
require the same frequency of routine maintenance that the
HID technology requires. By discontinuing Option "B",
Idaho Power could also eliminate the four-year maintenance
required by customer-owned lamps that may lead to a
reduction in staffing. Further, Idaho Power could reduce
the number of catalog items it stocks in inventory for
lighting fixtures. The proposed change to LED from HID
lighting will reduce the overall- number of stocked products
and consol-idate the number of catalog items from twenty to
el-even.
O. Are there other factors that should be
considered regarding the Company's request to discontinue
Option \\B" under Schedule 4L?
Yes. Idaho Power is
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provider
fixtures;
that performs maintenance
not the only servj-ce
on customer-owned
other busj-nesses in southern Idaho currently
PATTESON, DI 18
Idaho Power Company
1 provide this servj-ce. In fact, almost aI1 cities taking
2 service under Option \\B" of Schedul-e 47 already own other
3 fixtures that they maintain under Option \\C" of Schedule
4 4]-.
5 Q. When does the Company propose to discontinue
6 maj-ntenance of customer-owned HID street lights under
7 Option \\B" of Schedul-e 47?
I A. Idaho Power proposes that all existing
9 Schedul-e 418 customers transition to Option \\A" or to
10 Option \\C" of Schedul-e 4l at a date of their choosing over
11 the next four years, but not later than September 30, 2023.
L2 This coincides with the same period of time that Idaho
13 Power plans to complete the replacement of al-l Company-
74 owned lighting systems with LED light fixtures.
15 0. Did the Company consul-t with Schedul-e 41B
L6 customers prior to the date of this filing?
L1 A. Yes. The Company consul-ted with all Schedule
18 41B customers (42 cities) during the fall of 2018 to
L9 understand the impact to each if the Company were to
20 receive Commission approval to el-iminate option \\B" in
2l Schedule 41.
22 O. Generally, what did the Company hear from the
23 Schedule 41B customers?
24 A. Overall, customers were receptive to the idea
25 of transitioning f rom Option \\B'l to Option \\A" or "C".
PATTESON, Df 19
Idaho Power Company
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Customers
evaluating
As
were also pleased to learn that Idaho Power was
a move to LED lighting technology.
several citi-esI mentioned previously,already
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maintain a number of their own street lights under Option
\\C" and were eager to real-ize the potential for cost
savings by moving from Option \\B" to "C". Some customers
indicated they wished to have Idaho Power assume ownership
of the lighting system and requested to be transitioned to
Option \\A" if Option \\B" were discontinued.
O. If its request is approved, how does the
Company plan to notify Schedule 418 customers of the
requirement to convert to Options \\A" or "C".
A. The Company intends to personalJ-y contact each
!2
13
74 customer taklng service under Schedul-e 418 and wil-l- work
15 with those customers to develop a transition p1an.
t6 IV. REVENITE REQUTREMENT IMPACT Ar{ArYSrS
L1 Has the
10
l,
the conversion
Company determined what, if dDy,
project will have on Idaho Power's1B
79
20
2t
22
23
24
25
impact
annual-revenue requirement?
A Yes. The Company completed an analysis that
quantified the present
over a 2l-year period
proj ect .
The analysis compared
difference based on updated,
value revenue requirement impact
of implementing the conversion
the annual- revenue requirement
current costs between two
PATTESON, Dr 20
Idaho Power Company
1
2
3
4
tr
6
1
o
9
scenarios: (1) a scenario in which the Company did not
replace its exlsting Company-owned lighting systems (the
business-as-usual- scenario) and (2) the replacement of
existing Company-owned lighting systems with LEDs (the LED
conversion scenario) . It should be noted that the 20L9
revenue requirement is a partial year and reflects the
conversion to LEDs beginning in October 201,9. The full
conversion is not expected to be completed until September
2023, and therefore, the full year revenue requirement
10 impacts are seen beginning in 2024.
11 This revenue requirement analysis l-ooked at
t2 incremental costs associated with the conversion of
13 existing Company-owned lighting systems to LED opti-ons as
14 compared to a no change or "business-as-usuaf scenario."
15 This revenue requirement analysis is based on the estimated
16 costs of the existing Company-owned lighting systems
77 compared to the estimated costs of replacing existing
18 Company-owned lighting systems with LEDs and does not
19 refl-ect what the Company is collecting from customers
20 through its Schedule 4l and Schedul-e 15 rates.
2I O. What are the results of the present value
22
23
24
revenue requirement
A. During
near-term reductions
analys i s ?
the transition to LEDs, there are some
PATTESON, Dr 27
Tdaho Power Company
in the Idaho jurisdictional revenue
25 requirement (first three years) and some near-term
1
2
3
A
5
6
1
B
v
increases in the Idaho jurisdictional revenue requirement
(next three years) . Overaff, the Company's Idaho
j urisdlctional revenue
approximately $548, 000
mill-ion over a 20-year
value basis.
O. Have you
requirements
O.
20 rates as part
2L A
22 rates as part
23 modify its tariff to
anticipation of the
Schedules 15 and 4l
Z4
requirement woul-d be reduced by
over a 6-year period and $2.3
period (2079-2038) on a net present
for the LEDs.
Is fdaho Power requesting to change customer
of this filing?
No, the Company is not requesting to change
of this case. The Company requests only to
prepared an exhibit demonstrating the
estj-mated annual revenue requirement impact?
A.Yes. Exhibit No. 3 provides a summary of the
10 potential future cost savings beneflts of transitioning to
11 LED lighting fj-xtures presented in the form of an annual
72 revenue requirement analysis.
13 O. What is driving the Iower annual revenue
74 requirements?
15 A. The annual revenue requirements under the LED
L6 conversion scenario primarily provides for lower operations
L7 and maintenance expense amounts due to lower maintenance
1B
19
allow LED technology to be deployed in
HID technology's obsolescence. Because
specify a certain type of lighting
PATTESON, Dr 22
Idaho Power Company
25
1
2
3
4
5
6
1
B
9
technology (HID technology), the Company is unabl-e to
simply replace those obsol-ete materials without Commission
approval.
It is al-so important to note, current revenue from
Schedul-es 15 and 4L related to the cost components at issue
in this case is lower than the current revenue requirements
of both the business-as-usuaI scenario and the LED
instal-lation scenario. Therefore, a rate increase could be
supported for either scenario. However, it is not the
Company's intent to use this filing as a vehicle to
increase rates for Schedule 15 and 47 customers. The
Company's expectatlon is that it will seek to incl-ude any
new rate base required to provi-de service to Schedules 15
and 4l in base rates in a future rate proceeding. However,
the benefit attributable to l-ower energy consumption
resulting in net power supply expense savings wil-l be
real-ized through the PCA annually upon deployment of the
LED technology.
O. Cou1d the revenue requirement quantification
presented on Exhibit No. 3 be ut.ilized to inform a rate
change?
A. No. The revenue requirement analysis
presented on Exhiblt No. 3 was developed to determine the
long-term economics of moving to the LED technology and to
assess the cost-effectiveness of LEDs, and therefore, onJ-y
PATTESON, Dr 23
Idaho Power Company
10
11
t2
13
74
15
L6
L1
1B
19
20
27
22
z3
24
25
1 evaluates the revenue requirement components associated
with the technology change. A fulI cost-of-service
analysis
properly
for the affected classes would be required to
inform a rate adjustment. Such an
2
3
Aq
5
6
1
U
9
analysis is
case and wouldbeyond the scope of
be better addressed
comprehensive revj-ew
issues presented in this
in a proceeding where a more
of cost-of-service is performed.
V. PROPOSED TARIFF CTIATiIGES
What changes is the Company prosing to
and 47?
The Company's proposed tariff changes for
are refl-ected in Attachment 1 to the
The Company's proposed tari-f f changes for
theare reflected in Attachment 2 Lo
What specific changes does Idaho Power propose
10
0.
Schedules 15
A.
Schedul-e 15
Application.
Schedu.l-e 4L
Application.
o.
for Schedule
11
72
13
L4
15
76
71 15?
18 A. As more fully described above, the Company is
t9 proposing changes to Schedule 15 that wil-l- (1) add language
20 to indicate that high pressure sodium vapor lighting
2L systems and metal halide lighting systems wil-I no longer be
22 avallable for new installations as of October t, 20L9, and
23 (2) outline the proposed wattage and lumen ranges
24 identified as the LED replacements for existing high
25 pressure sodium vapor lighting systems.
PATTESON, Dr 24
Idaho Power Company
1
2
3
4
5
6
1
U
9
O. What specific changes does Idaho Power propose
for Schedul-e 47?
A. As more fully described above, the Company is
proposing changes to Schedule 4L that will- (1) add language
to Option \\A" to indicate that hiqh pressure sodium vapor
lighting systems will no longer be availabl-e for new
instal-lations as of October 7, 2019, (2) add language
providing an option for customers to request a shield be
installed, at their expense, oo an LED fixture, (3) outl-ine
the proposed wattage and l-umen ranges identified as the LED
replacements for existing high pressure sodj-um vapor
lighting systems under Option "A", (4) add language to
indicate the cl-osure of Option \\B" effective September 30,
2023, and (5) for housekeeping purposes, (a) where
necessary, add language to specify whether the tariff
provision applies to high pressure sodium vapor or LED
fi-xtures and (b) remove the "Ornamental Lighting
Customer-Owned System" section of Schedule 41. Ornamental
lighting was closed to new service after October 31, 1981,
and through attrition, no customers remain under this
service offering.
VI. CUSTOMER COMMT'NICATION
10
11
L2
13
L4
15
16
t1
1B
L9
20
2t
ZZ
23 Did the Company consult with customers prior
24 to the date of this filing?
25
PATTESON, Dr 25
Idaho Power Company
1
2
3
4
5
6
1
B
9
A Yes.
take service under
The Company
Schedule 4l stakehol-ders to the
Idaho Power met
about the
street
of their
happy to
LED
Iearned"
identified 46 cities who
as key
Company.changes being
with these 46
O.
receive from
A.
hear that Idaho
technology. A
from their own
proposed by the
cities prior to
GeneralJ-y, what
the cities?
filj-ng this application.
feedback did Idaho Power
10
OveraII, the cities
potential LED replacement of the
Iights. Some cities have already
customer-owned street lights with
were positive
Company-owned
replaced many
LEDs and were
Power was considering a move to
few cities al-so shared "Iessons
11
t2
13 conversions. Those cities explained that
14 most of the feedback they received from
15 the LED light fixtures were with
t6 of the LED light or
customers regarding
to either the cofor
for a shiel-d to be
regard
the need
l1
temperature
installed on the LED light to prevent glare. These cities
18 reconrmended the Company install- LED street lights rated at
L9 3,000K or l-ess because, in their experience, customers
20 preferred the 3,000K or less col-or temperature.
27 0. Did the Company take that feedback into
22 consideration when preparing its proposed LED changeout
23 plan?
24 A. Yes. As I mentioned previously, the LED light
25 fixtures proposed for all area liqht and street light
PATTESON, Dr 26
Idaho Power Company
1 fixtures are 3,000K and are dark-sky lighting compliant,
2 with an option for a shield (upon request) at the
3 customer's expense. The only exception to the 3,000K are
4 the flood light fixtures util-ized in Schedul-e 15, which are
5 4,000K. This decj-sion was partially informed by the
6 feedback obtained from the cities.
1 Q. What other efforts has the Company made to
8 inform customers of the filing?
9 A. The Company has created a webpage for the LED
10 Conversj-on Project. The webpage was made available as of
11 the date of this filing and can be found at
L2 www.idahopower/lnO.com. The webpage contains frequently
13 asked questions to answer the most common questions that
I4
15 frequently asked
L6 questions are incl-uded as Exhibit No. 4.
Ll The Company also plans to personally contact al-l-
18 customers t.aklng service under Option \\A" or \\B" of
19 Schedule 4t to inform each customer of the filing. The
20 Company representative wiIl provide the customer with a
2L letter to inform Schedule 41A and 478 customers of the
22
customers may have and a phone number
have additional questions. A draft of
filing and how they would be impacted,'
proposes to replace all Company-owned
with an equivalent LED fixture and to
to caII if customers
that is, the
23
.AZL+
street J-ight
di-scontinue
Company
fixtures
servr-ce
25 under Option "B". The letter also provides information as
PATTESON, Dr 21
Idaho Power Company
1 to how those customers could submit a comment for the
2 Commission's consideration. A draft of the fetter is
3 inc]uded as Exhibit No. 5.
4 For Schedule 15 customers, the Company will send a
5 bill insert to Schedu1e 15 customers subsequent to the
6 filing of the AppJ-ication to inform them of the filing.
7 The bill insert will- include the web address of the
8 Commission website, the web address of Idaho Power's LED
9 Conversj-on Project website, and will provide a phone number
10 for customers to contact Idaho Power wlth additlonaf
11 questions. A draft of the bitl insert is included as
L2 Exhibit No. 6.
13 IfO
14 inform customers
approved, how does Idaho Power plan to
of the tariff changes and LED replacement
15 plan?
76 A Upon Commission approval, the
all customersL1 once again personally contact.
79
under Option \\A" or \\B// of Schedule 4l. A
representative wil-l- inform each customer of
20
2t
22
23
24
Company wil-l-
taking service
Company
the
1B
Commission's decislon in
implementation p1an.
Additionally, at
the case and discuss the Company's
the time the Company performs the
LED replacement for Schedule 15 customers, Idaho Power wiIl
leave a doorhanger explaining that the light was replaced
PATTESON, DI 28
Idaho Power Company
Z5
2
3
4
5
6
1
x
9
1 with an LED. A draft of the doorhanger is included as
Exhibit No. 1
VII. CONCLUSION
O. Please summarize the Company's request in this
proceeding.
A. Idaho Power is requesting approval to modify
Schedu1e 15 and Schedule 4L to al-l-ow for the replacement of
al-l- HID Company-owned lighting systems with LED light
fixtures and to discontinue maintenance of customer-owned
HID Ij-ghting systems by transitloning customers from Option
\\B// of Schedul-e 4L to either Option \\C" or Option \\A'r by
September 30, 2023.
Idaho Power is requesting that the Commissj-on issue
an order authorizing the Company to modify Schedule 15 and
Schedule 4t to al-Iow for LED technology, to el-iminate the
option for new installations of Company-owned HID area
lights and street lights going forward effective October 7,
2019, and the closure of Option \\B" of Schedule 4L to
service effective September 30, 2023.
O. Why shoul-d the Commission approve the
Company's request?
A. Continuing to install and maintain HID
technology wiJ-1 result in higher costs for lighting
customers due to upward pressure on HID lighting costs as a
resul-t of its impending obsolescence. The reduction in
10
11
T2
13
74
15
L6
71
1B
79
20
2L
ZJ
Zq
PATTESON, Dr 29
Idaho Power Company
25
1 cost for LED lighting has created parity in J-ighting
2 options that makes it a viable option for fdaho Power to
3 move to LED street and area lighting. Eurthermore, the
4 move to LED lighting is responsive to customers'
5 preferences, furthers energy efficiency, promotes
6 environmental stewardship, and wil-I increase customer
7 satisfaction.
B Q. Does this conclude your testimony?
9 A. Yes, it does.
10
11
72
13
74
15
76
71
1B
79
20
27
22
23
24
PATTESON, Dr 30
Idaho Power Company
25
1
Z
3
4
5
6
1
B
9
ATTESTATION OF TESTIMONY
STATE OF IDAHO
SS.
County of Ada
I, Kristy M. Patteson, having been duly sworn to
testify truthfulJ-y, and based upon my personal knowledge,
state the followj-ng:
I am employed by Idaho Power Company as the
Regulatory Analyst and am competent to be a witness in this
proceeding.
I declare under penalty of perjury of the laws of
the state of Idaho that the foregoing rebuttal testimony is
true and correct to the best of my information and belief.
DArED this Aq\"y of May, 20Ls.
Kr yM at C5 Aday of
79 M"y, 2079.
10
11
72
13
l4
15
t6
t1
1B
20
2L
1')
23
24
25
26
21
2B
4ySUBSCRIBED AND SWORN to before me thls
No ry Publ
,^)Ll-Lo
Residing at
for Idaho
ise, Idaho
My commission expj-resz 72/20/20
PATTESON, Dr 31
Idaho Power Company
KIMBERLY K. TOWELL
coMMlssloN #169s8
NOTARY PUBLIC
STATE OF IDAHO
29
BEFORE THE
IDAHO PUBLIC UTILITIES GOMMISSION
CASE NO. IPC-E-19-17
IDAHO POWER COMPANY
PATTESON, DI
TESTIMONY
EXHIBIT NO. 1
Parking Lot Lighting Before LEDs
Parking Lot Lighting After LEDs
Exhibit No. 1
Case No. IPC-E-19-17
K. Patteson, IPC
Page 1 of 1
"'+
-.: i -':-'* tF
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-r " i
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BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
GASE NO. IPC-E-19-17
PATTESON, DI
TESTIMONY
EXHIBIT NO.2
IDAHO POWER COMPANY
COUNTS BY LAMP TYPE AND WATTAGE
AS OF MARCH 2019
Schedule 15 Lighting Systems
Schedule 15 Lamp Types ldaho
Area Lamps
100W High Pressure Sodium
200W High Pressure Sodium
400W High Pressure Sodium
Flood Lamps
200W High Pressure Sodium
400W High Pressure Sodium
400W Metal Halide
1000W Metal Halide
7,565
700
104
838
419
119
69
9,814
Schedule 41A Lighting Systems
Schedule 41A Lamp Types ldaho
70W High Pressure Sodium
100W High Pressure Sodium
200W High Pressure Sodium
250W High Pressure Sodium
400W High Pressure Sodium
109
14,829
1,674
267
118
16,998
Exhibit No. 2
Case No. IPC-E-19-17
K. Patteson, IPC
Page 1 of 1
BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
GASE NO. IPC-E -19-17
IDAHO POWER COMPANY
PATTESON, DI
TESTIMONY
EXHIBIT NO.3
Exhibit No. 3
Case No. IPC-E-19-17
K. Patteson, IPC
Page 1 of4
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Case No. IPC-E-19-17
K. Patteson, IPC
Page 3 of 4
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Case No. IPC-E-19-17
K. Patteson, IPC
Page 4 of 4
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BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
GASE NO. IPG-E -19-17
IDAHO POWER GOMPANY
PATTESON, DI
TESTIMONY
EXHIBIT NO.4
FREQUENTLY ASKED QUESTIONS
ldaho Power Company ("ldaho Powe/') recently made a filing with the ldaho Public Utilities Commission
("Commission") requesting approvalto change all area light, flood light, and ldaho Power-owned street
light fixtures from high pressure sodium ('HPS') light fixtures to light-emitting diode ('LED") light fixtures.
lf approved, ldaho Power anticipates starting the changeout in Fall 2019.
Why is ldaho Power requesting the change to LED street Iights and area lights?. Due to changing technology within the lighting industry, the Company has less certainty
regarding the future availability of the existing HPS technology.. LED lights provide significant advantages over the existing HPS lights. LED lights provide better
lighting quality, consume less energy, and require less maintenance.
lf I have a street light or area light account, can I decline the change to an LED?. No. lf approved as filed, ldaho Power will no longer maintain an inventory of HPS lights as the
transition is made to LED street lights. ldaho Power will replace all ldaho Power-owned street
light fixtures with LED light fixtures.
When wi!! ldaho Power begin replacing the old fixtures with the LED fixtures?o With Commission approval, ldaho Power will begin replacing existing light fixtures with LED
fixtures in late Fall 2019. The project is expected to take approximately four years to complete.
Will the LED light fixtures look different than the existing street light fixtures?o The LED light fixtures will look similar to the existing HPS fixtures.
Are LED lights brighter than the existing light fixtures?. The light quality of the LED light fixture is visually different than light produced by the existing
HPS fixtures. HPS street lights produce a light color with a yellowish or orange hue, whereas
the color temperature of LED lights is whiter with better color rendition, thus providing greater
clarity. LED lights also project light in a focused pattern, directing light more precisely where it
is needed. The result is more uniform light coverage, with less glare and fewer dark spots, which
improves visibility.
What color temperature has ldaho Power selected for the LED fixtures?. ldaho Power expects that all street light fixtures under Schedule 41(A) will be 3,000 Kelvin ("K").
ldaho Power has identified cobra-head LED fixtures that comply with lnternational Dark-Sky
Association standards for shielding, which minimizes glare and light spillage.. The only exception to the 3,000K expected is the Schedule 15 flood lights, which are specified
at 4,000K. Schedule 15 flood lights are specified at 4,000K because many of the existing flood
light fixtures utilize metal halide lamps operating at approximately 4,000K. This type of lighting
is not dark-sky compliant due to the nature of a flood light fixture in general.
Willthis changeout affect my power bil!?. ldaho Power is not requesting a rate change with this filing
About ldaho Power
ldaho Power, headquartered in Boise, ldaho, and locally operated since 1916, is an energy company
that employs approximately 2,000 people who serve more than 550,000 customers throughout a
24,OO0-square-mile area in southern ldaho and eastern Oregon. With 17low-cost hydroelectric projects
as the core of its diverse generation portfolio, ldaho Power's residential, business, and agricultural
customers pay among the nation's lowest prices for electricity. IDACORP lnc. (NYSE: IDA), ldaho
Power's independent publicly traded parent company, is also headquartered in Boise, ldaho. To learn
more, visit idahopower.com or idacorpinc.com.
Exhibit No.4
Case No. IPC-E-19-17
K. Patteson, IPC
Page 1 of 1
BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
GASE NO. IPC-E -19-17
IDAHO POWER GOMPANY
PATTESON, DI
TESTIMONY
EXHIBIT NO.5
3Iffi*.
An IDACORP Company
Insert Date]
Insert Recipient Name]
Insert Recipient Title]
Insert Recipient Company]
Insert Recipient Street Address]
Insert City, State Zip]
Subject Modification to Streetlighting Service
Dear Insert Recipient]
As it has for more than 100 years, Idaho Power is pleased to offer streetlighting services to our customers.
As a current streetlighting customer, we want to let you know that on May 24,20L9,ldaho Power filed a
request with the Idaho Public Utilities Commission (IPUC) to modiff its streetlighting service to reflect
changing lighting technology.
Idaho Power is requesting to replace all company-owned streetlight fixtures with light-emitting diode
(LED) fixtures. LED lights provide better lighting quality than the currently installed high-pressure sodium
lights. They also use less energy and require less maintenance. Idaho Power is proposing to perform the
replacement of existing fixtures over a four-year period, in lieu of routine maintenance.
Concurrent with the switch to LEDs, Idaho Power is requesting to discontinue Company maintenance of
customer-owned light fixtures. The Company is proposing that all fixtures owned by the customer, but
maintained by the Company, transition to Option C of Idaho Power's tariff Schedule 41, Customer-Owned,
Customer-Maintained System or to Option Au Idaho Power-Owned, Idaho Power-Maintained System, by
September 30,2023.1f transitioning to Option C, the Company will work with customers who continue to
have non-metered seasonal or variable energy use, to remove or meter the variable usage by September
30,2023.
I invite you to learn more about the proposal. Copies of the application are available to the public at the
Commission offices (472W. Washington St., Boise) or on Idaho Power's website,
r,wvw.idahopower/LED.com or the IPUC website, www.puc.idaho.gov. To submit a comment on the
proposal, visit vwvw.puc.idaho.gov. Under the "Consumers" heading, click on "Case Comment Form," and
include the case number, IPC-E-79-77.
Please contact your enerry advisor if you have questions. Thank you for being an Idaho Power customer,
We value your business!
Exhibit No. 5
Case No. IPC-E-19-17
K. Patteson, IPC
Page 1 of 1
Sincerely,
BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
cAsE NO. IPC-E-19-17
IDAHO POWER COMPANY
PATTESON, DI
TESTIMONY
EXHIBIT NO.6
I
ldaho Power is proposing to replace
all existing area light and flood light
fixtures with LED (light-emitting diode)
fixtures.
The LED lights are cleaner, will provide better
lighting quality and require less maintenance.
lf you have questions, please contact our energy
advisors at 1-800-632-6605 or visit our website
for more information.
idahopower.com/LED
ftffi*
Exhibit No. 6
Case No. IPC-E-19-17
K. Patteson, IPC
Page 1 of 2
An loacoRP conrDinv
muffi.@tr
T
1Ir'.
u
t.l
Proposal for LED Lights
for LighG
As a customer with an area or flood light, we
want to let you know that on May 24,20'19,ldaho
Power filed a request with the ldaho Public Utilities
Commission (IPUC) to replace existing
high-pressure sodium and metal halide lights with
light-emitting diode (LED) fixtures, which provide
better lighting quality, consume less energy and
require less maintenance.
lf approved as proposed, the project would begin
in fall 2019 and would take about four years to
complete. ldaho Power proposes changing out
lights on its regular four-year maintenance schedule
To learn more about the proposal, visit the IPUC
website at puc. idaho.gov.
lf you have questions, please contact our energy
advisors at 1-800-632-5605 or visit our website
for more information.
idahopower.com/LED
ftffi*@ 2019 ldaho Power
3 I I 80-t-0040
Exhibit No. 6
Case No. IPC-E-19-17
K. Patteson, IPC
Page 2 of 2
An IDACORF Comprny
h,
rt ll,I
BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
GASE NO. IPC-E-19-17
IDAHO POWER COMPANY
PATTESON, DI
TESTIMONY
EXHIBIT NO.7
I
Exhibit No. 7
Case No. IPC-E-19-17
K. Patteson, IPC
Page 1 of 1
elmlo Pcm,ER.
An l0AcoRP CompanV
ldaho Power has replaced the area light
at this address with an LED (light-emitting
diode) fixture.
This new light will provide better lighting
quality and require less maintenance.
lf you have questions, please contact one
of our energy advisors at 1-800-532-5505
or visit our website for more information.
idahopower.com/LED
ItuE@tr
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hts
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New LED