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Home My WebLink About20220209Comments.pdfEric L. Olsen 0SB# 481l) ECHO HAWK & OLSEN, PLLC 505 Pershing Ave., Ste. 100 P.O. Box 6l 19 Pocatello, Idaho 83205 Telephone: (208) 47 8 -l 624 Facsimile: (208) 47 8-167 0 Email: elo@echohawk.com rrlr'Jt1/If-r;'ri-l/.-I r'uL/ ,, ::ij -9 PH 3: 5 j i,*ii/j:.,iissi0l\ Attornqtfor Intervenor Idaho lrrigation Pumpers Association, Inc. BEFORE THE IDAIIO PUBLIC UTILITIES COMMISSION IN THE MATTER OF IDAHO POWER COMPAI\TY'S APPLICATION FOR APPROVAL TO MODIFY ITS DEMAND RESPONSE PROGRAMS CASE NO. IPC-E-2I.32 IDAIIO IRRIGATION PUMPERS ASSOCIATTON, rNC.',S COMMENTS RE: IDAHO POWER'S APPLICATION COMES NOW the Idaho Irrigation Pumpers Association, Inc. ("IIPA") and pursuant to Commission's OrderNo.35266 and provides its comments inresponseto Idaho PowerCompany's ("Idaho Power") Application for Approval to Modiff lts Demand Response Programs. IIPA supports ldaho Power's application to modifr its existing demand response progftrms. IIPA has reviewed Idatro Power's application and testimony, participated in multiple technical workshops, and submitted and reviewed discovery. IIPA has held informal discussions with ldaho Power and current and potential Irigation Peak Rewards Program customers to identiff and resolve potential issues with Idaho Power's application. IIPA frnds that the proposed modifications to the Lrigation Peak Rewards Program will improve the value of the program to Idaho Power's system. While the proposed modifications will increase the burden of the program on participants, this burden appears to be appropriately offset by increased incentive payments, and is waranted given the evolving nature of Idaho Power's system demand needs. The modified Irrigation Peak Rewards Program burdens participants by: IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.'S COMMENTS - Page I l. Shifting the time of curtailment later into the night; 2. Increasing the weekly limit to curtailed hours; 3. Extending the season of curtailments; and 4. Removing the variable incentive payment for the fourth curtailment of the season. The most substantive change from IIPA's perspective is the shift in the time of curtailments. Idaho Power proposes to shift the focus of the progmm design to account for the impact of growing solar generation on Idaho Power's system. The growth of solar has shifted the optimal value for irrigation curtailment later into the evening. Idaho Power proposes shifting the curtailment window two hours later in the day. The program currently curtails customers between I pm and 9 pm. Idaho Power proposes a new curtailment window of 3 pm to I I pm. Many current program participants face technical and labor challenges associated with late- day curtailments due to issues associated with restarting their irrigation systems. IIPA discussed these difficulties with Idaho Power and understands that Idaho Power works proactively to minimize the negative impacts of late day curtailments on customers. Some IIPA members will likely reduce participation in the demand response program. However, IIPA expects that the modified program will continue to have material participation rates from existing participants. The remaining modifications to the Peak Rewards Program do not raise any material concerns for IIPA. Idaho Power's application incudes increased fixed and variable incentive payments. IIPA finds that the revised incentive payment is sufficient to attract program participants while still being substantially lower than the avoided cost of the program. Idaho Power estimates the avoided cost of DR capacity to be $51.42 per kW per year.r I Direct Testimony of Quintin Nesbit page 32. IDAHO IRRJGATION PUMPERS ASSOCIATION, INC.'S COMMENTS -Page 2 Administration, Labor & Marketing w/ De{ce Maint.Aoorox Max Reallz Rate s 235.000 Fixed hc€nti\e UkWseason L6ss Opt Out Fee o.72 $24.0 Variable lncenti\e $/kWseason New Nomlnadon kW=u5,44 $1.02 Existino De\ice Numberc 1,7{,NewTotal Capaclw kW =2,l8,000 Prooram Reduction %25% Added Derices & Elamand Reduction 130 1n 'tl,201 Added Derices & lnstallation Cost $566.00 $73.580 Charue to Maintenance Costs $ (23,6601 Added Adwrtisim ard Admin Cocts $ 10.000 Fixed lncentiw Cost $ 7.,t67.978 Expected Variable lncenti\€ e,ost $ 315,837 Iotal Costs without Variable $ 7.762,898 Iotal Costs without Variable SkWf/r 3 31.30 Iotal Costs w/ Variable Total Prosram Cost $I 8,07E,735 Iotal Costs d Variable Cost $/kW/yr t 3258 The table below summarizes the expected cost of the Irrigation Peak Rewards Program under the proposed incentive payment, assuming curtailments consistent with 2018 through 2021:2 The avoided cost ofthis program under [daho Power's assumptions is $51.42 per kW. The expected cost ofthe program is $32.58. The difference between avoided cost and expected cost, $18.84, represents the levelized benefit of this program for rate payers. While IIPA believes that a higher incentive payment can be justified, IIPA is willing to support the proposed incentive structure on a provisional basis pending review of the impact of the proposed sfuanges on program participation rates. At the proposed incentive rates the program is cost effective. Idaho Power intends to open enrollment in the lrrigation Peak Rewards Program. IIPA supports this decision. The Irrigation Peak Rewards Program is a cost effective, sustainable, and low risk solution for meeting Idaho Power's peak energy needs. Idaho Power's IRP demonstrates on-going capacity needs that can be met through expansion of the Peak Rewards Program. The expected cost of this program is substantially below the cost of an equivalent simple cycle combustion turbine after accounting for other economic benefits. The demand response program presents significantly less environmental risk than a gas turbine because it is a non-emitting 2 Calculated from data provided in Idaho Power response to IIPA DR 9 and the Idaho Power January 31,2022 Technical Workshop. IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.'S COMMENTS - Page 3 resource and will be unlikely to be exposed to future state or federal regulation. It presents less financial risk because it does not involve large up-front capital expenditures. Idaho Power has agreed to continue to collaborate with IIPA on an informal basis to continue evaluating and improving the lrrigation Peak Rewards Program. IIPA believes that continued development of the peak rewards program could lead to overall growth in the size of the program and ultimately greater value for Idaho Power customers. IIPA recommends the commission approve Idatro Power's application as filed. DATED this 9m day of February,2}22. ECHO HAWK & OLSEN ERIC L. OLSEN IDAHO IRRIGATION PUMPERS ASSOCIATIO\ INC.'S COMMENTS - Page 4 CERTIFICATE OF SERYICE I HEREBY CERTIFTY that on this 9ft day of February,2022,I served a true, correct and complete copy of the Petition of ldaho Irrigation Pumpers Association, [nc. for Leave to lntervene to each of the following, via U.S. Mail or private courier, email or hand delivery, as indicated below: Jan Noriyuki, Secretary Idaho Public Utilities Commission P.O. Box 83720 I l33l W. Chinden Blvd. Building 8, Suite 201-A Boise,ID 83714 i an. noriyuki (a)puc. idaho. eov Lisa D. Nordstrom Connie Aschenbrenner Idaho Power Company l22l West Idaho Street (83702) P.O. Box 70 Boise,Idaho 83707 lnordstrom@ idahopower. com ca schenbrenner@ idahopow er. com dockets@idahopower.com Riley Newton, Deputy Attorney General Idaho Public Utilities Commission 11331 W. Chinden Blvd., Bldg No. 8, suite 201-A (83714) PO Box 83720 Boise, lD 83720-0074 ri ley. newton(a)puc. idaho. eov Lance Kauftnan Aegis Insight 4801 W. Yale Ave. Denver, CO 80219 lance@ae gisinsieht. com U.S. Mail Hand Delivered Overnight Mail Telecopy (Fax) Electronic Mail (Email) U.S. Mail Hand Delivered Overnight Mail Telecopy (Fax) Electronic Mail (Email) U.S. Mail Hand Delivered Overnight Mail Telecopy (Fax) Electronic Mail (Email) U.S. Mail Hand Delivered Overnight Mail Telecopy (Fax) Electronic Mail (Email) trx trutrtrx II IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.'S COMMENTS - Page 5 Benjamin J. Otto Emma E. Sperry Idaho Conservation League 710 N. 6th Street Boise, D 83702 botto@ idahoconservation. ore espeny@ idahoconservation. org Peter J. Richardson Richardson, Adams, PLLC 515 N. 27th Street PO Box 7218 Boise, lD 83702 peter@ richardsonadams. com Dr. Don Reading 6070 Hill Road Boise,ID 83703 dreadine@mindsprine. com Jim Swier Micron Technology, Inc. 8000 South Federal Way Boise,ID 83707 iswier@micron.com Austin Rueschhoff Thorvald A. Nelson Austin W. Jensen Holland & Harf LLP 555 17th Steet Suite 3200 Denver, CO 80202 darueschho ff(E hol I andhart. com tnel son@ hollandhart. com awj ensen@hollandhart. com aclee@hollandhart. com ql gareanoamari@hollandhafi . com U.S. Mail Hand Delivered Ovemight Mail Telecopy (Fax) Electronic Mail (Email) U.S. Mail Hand Delivered Ovemight Mail Telecopy (Fax) Electronic Mail (Email) U.S. Mail Hand Delivered Overnight Mail Telecopy (Fax) Electronic Mail (Email) U.S. Mail Hand Delivered Overnight Mail Telecopy (Fax) Electonic Mail (Email) U.S. Mail Hand Delivered Ovemight Mail Telecopy (Fax) Electronic Mail (Email) ntr trtrtrtrx trtr Ix IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.'S COMMENTS - Page 6 Ed Jewell, D€euty City Attomey BofoG City Attorney'r Offoc 150 N. Capitol Blvd. PO Box 500 Boise,ID 83701-0500 ej ewell@ciwofboise.ore boiseciwamornw@cityofboise. org u.s.Ivlsil HandDotvered Ov€mie[t Mail Telecopy (Fax) Electunic lvlail (Email) ERIC L. OLSEN IIIAHO IRBIGAIION PLMPERS ASSOCIATION, INC.'S COIIMENIII - Prge 7