20230124Reply Comments.pdf

Megan Goicoechea Allen
Corporate Counsel
[e-mail]
January 24, 2023
VIA ELECTRONIC FILING
Jan Noriyuki, Secretary
Idaho Public Utilities Commission
11331 W. Chinden Blvd., Bldg 8,
Suite 201-A (83714)
PO Box 83720
Boise, Idaho 83720-0074
Re: Case No. IPC-E-22-24
In the Matter of the Application for a Modification to Add an Automatic
Dispatch Option to the Company’s Commercial & Industrial Demand
Response Program, Schedule 82
Dear Ms. Noriyuki:
Attached for electronic filing, please find Idaho Power Company’s Reply Comments in
the above matter.
If you have any questions about the attached documents, please do not hesitate to
contact me.
Very truly yours,
Megan Goicoechea Allen
MGA:sg
Attachments
RECEIVED
Tuesday, January 24, 2023 4:10:24 PM
IDAHO PUBLIC
UTILITIES COMMISSION

IDAHO POWER COMPANY’S REPLY COMMENTS - 1
MEGAN GOICOECHEA ALLEN (lSB No. 7623)
LISA D. NORDSTROM (ISB No. 5733)
Idaho Power Company
1221 West Idaho Street (83702)
P.O. Box 70
Boise, Idaho 83707
Telephone: [phone]
Facsimile: [phone]
[e-mail]
[e-mail]

Attorneys for Idaho Power Company

BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION

IN THE MATTER OF THE APPLICATION
OF IDAHO POWER COMPANY FOR
MODIFICATION TO ADD AN AUTOMATIC
DISPATCH OPTION TO THE COMPANY'S
COMMERCIAL & INDUSTRIAL DEMAND
RESPONSE PROGRAM - SCHEDULE 82.
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CASE NO. IPC-E-22-24

IDAHO POWER COMPANY’S
REPLY COMMENTS

COMES NOW, Idaho Power Company (“Idaho Power” or “Company”), pursuant to
Idaho Public Utilities Commission (“Commission”) Rule of Procedure 203 and the Notice
of Modified Procedure, Order No. 35551, respectfully submits the following Reply
Comments in response to Comments filed by the Commission Staff (“Staff”) on January
10, 2023.
I. REPLY COMMENTS
In its Comments, Staff recommends the Commission grant the Company
authorization to implement the Voluntary Automatic Dispatch Option for the Flex Peak
Program.1 More specifically, Staff makes the following recommendations:

1 Staff Comments at 2.

IDAHO POWER COMPANY’S REPLY COMMENTS - 2
1. That the Commission authorize the Company to modify Schedule 82, Flex
Peak Program, of Idaho Power's I.P.U.C. No. 29 Tariff No.101, as filed; and
2. That the Company document instances when a customer is denied
participation in a Demand Response (“DR”) program, and instances when Load
Control Devices (“LCDs”) fail to communicate during an event.
The Company agrees with Staff’s recommendations and appreciates the
opportunity to offer these Reply Comments to briefly address, and hopefully alleviate,
concerns raised by Staff.
A. Unilateral Discretion to Deny Participation
Staff states that it “is concerned with the Company's unlimited discretion to accept
or deny participants and that the Tariff does not provide constraints for denying a
customer's participation.”2 Staff also acknowledges that the Tariff language has been in
place for all three DR programs prior to the Company’s Application, and the Tariff
language has not caused any issues thus far.3 The Company would like to reaffirm that
even though the Tariff language provides Company discretion, that discretion will
continue to be used in the best interest of all customers so that reliable load reduction
during DR events is achieved.
The Company would also like to highlight that application denials are a rare
occurrence for any of its DR programs. Specifically, for the Flex Peak program, the
Company has only denied one application over the last two years, due to the customer

2 Staff Comments at 3.
3 Id. at 4.

IDAHO POWER COMPANY’S REPLY COMMENTS - 3
not meeting the eligibility requirements contained within Schedule 824. In the event it is
determined that the Automatic Dispatch Option may not work for an otherwise qualifying
customer, the Company will provide the customer with the option of participating using
the current manual option.
As Staff notes, while the Company has experience with LCDs in its two other
programs, the configurations for potential Flex Peak participants are expected to vary by
customer as compared to Idaho Power’s A/C Cool Credit and Irrigation Peak Rewards
programs – that is, the installation is on a single piece of equipment, A/C units and
irrigation pumps respectively. For the Flex Peak Automatic Dispatch Option, each
customer’s setup is expected to differ in terms of the software, systems, hardware, and
the equipment that will need to be configured to provide load reduction during DR events.
Therefore, detailed coordination will be required with each customer. These complexities
could make the Automatic Dispatch Option not feasible for some customers.
As for program application documentation, the Company has an existing applicant
documentation process in place for all three of its DR programs that notes whether an
applicant was accepted or denied. Staff’s recommendation aligns with the Company’s
existing practices, and the Company will ensure the same documentation practices are
implemented for the Automatic Dispatch Option.
B. LCD Failures
Staff also states it is concerned that LCD failures may not be resolved in a timely
manner, and therefore, “Staff recommends that the Company investigate when failures

4 Customers must be capable of providing a minimum load reduction of 20 kW per Facility or an
aggregate reduction of 35 kW if participating under the Aggregated Option per Schedule 82 Page 82-1.
The customer did not meet the minimum load reduction requirements.

IDAHO POWER COMPANY’S REPLY COMMENTS - 4
occur and that the Company document such failures, the nature of the problem(s), and
the efforts to remedy the problem.”5 Staff’s recommendation is in line with existing
Company practices, as it already has LCD documentation and remediation practices in
place for its automated residential and irrigation DR programs. The Company commits to
implement these practices for the Commercial & Industrial (“C&I”) Automatic Dispatch
Option as well.
II. CONCLUSION
Idaho Power appreciates Staff’s support and confidence in the Company
implementing an Automatic Dispatch Option to the C&I Flex Peak Program. As noted in
its Application, the Company will need lead time to communicate and engage with
customers regarding the Automatic Dispatch Option, complete the appropriate device
testing to ensure the technology is working correctly from both the Company’s and
customer’s perspective, and enroll customers in preparation for the 2023 DR season. As
a result, the Company respectfully requests a final Commission determination by
February 15, 2023, so that it has sufficient time to complete the steps necessary for a
successful rollout of the Automatic Dispatch Option.
Idaho Power requests that the Commission issue an Order modifying Schedule
82, Flex Peak Program, of Idaho Power's I.P.U.C. No. 29 Tariff No.101, as filed and
validate the Company’s plan to document both denials of Automatic Dispatch Option
applicants as well as LCD failures and associated remediation efforts as described herein.

5 Staff Comments at 4.

IDAHO POWER COMPANY’S REPLY COMMENTS - 5
DATED at Boise, Idaho, this 24th day of January 2023.

________________________________
MEGAN GOICOECHEA ALLEN
Attorney for Idaho Power Company

IDAHO POWER COMPANY’S REPLY COMMENTS - 6
CERTIFICATE OF SERVICE

I HEREBY CERTIFY that on the 24th day of January 2023, 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
Chris Burdin
Deputy Attorney General
Idaho Public Utilities Commission
11331 W. Chinden Blvd., Bldg No. 8,
Suite 201-A (83714)
PO Box 83720
Boise, ID 83720-0074

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