HomeMy WebLinkAbout20230203Final_Order_No_35677.pdfORDER NO. 35677 1
Office of the Secretary
Service Date
February 3, 2023
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF IDAHO POWER
COMPANY’S APPLICATION FOR A
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
ORDER NO. 35677
On September 15, 2022, Idaho Power Company (“Company” or “Idaho Power”) filed an
Application with the Idaho Public Utilities Commission (“Commission”) requesting authority to
modify Schedule 82, Flex Peak Program, of Idaho Power’s I.P.U.C No. 29 Tariff No. 101
(“Schedule 82”). The Flex Peak Program (“Program”) is the Company’s Commercial & Industrial
Demand Response (“DR”) program used to reduce summer electricity demand during times of
high-risk system need. The Company proposed to add a voluntary Automatic Dispatch Option
Program like that of the A/C Cool Credit and Irrigation Peak Rewards programs.
The Company sought to implement the Automatic Dispatch Option for the 2023 DR season
that begins on June 15, 2023, and stated that a Commission order received by February 15, 2023,
along with a tariff effective coincident with a Commission order, would best position the Company
to accomplish this.
Currently, customers participating in the Program manually reduce load when the
Company calls DR events. The Company represented that customers nominate on a weekly basis
the load they would reduce if an event was called, and the customer’s performance based on
achieving their nominated load reduction is factored into incentive payments.
The Company’s proposed voluntary Automatic Dispatch Option for the Program involves
installing a device on-site either directly on the participating customer’s equipment, connected to
a customer’s energy management or building management system, or both. The Company stated
that when a DR load control event is called, the Company would continue to notify customers via
telephone, text, or email approximately four (4) hours before an event and would then send a signal
to the device(s) located at the customer’s premises at the start of the event to trigger load reduction
protocols.
ORDER NO. 35677 2
The Company asserted that because that method was already utilized in Idaho Power’s
other two DR programs, the Company already had experience and familiarity with the technology,
the process, and the execution of an automatic option.
The Company stated that the purpose of adding the Automatic Dispatch Option was to
increase Program capacity through increased participation and/or retention as short-term capacity
deficits were identified starting in 2023 in the Company’s most recently filed Integrated Resource
Plan. The Company also represented that its proposal did not impact the availability of the “Manual
Dispatch Option,” and current and potential customers would still be able to participate in the
Program manually, if preferred.
COMMISSION STAFF COMMENTS
Staff reviewed the Company’s Application and recommended the Commission grant the
Company authorization to implement the voluntary Automatic Dispatch Option for the Program.
Staff’s conclusion was based on: (1) the Company’s experience in automated dispatch options in
other DR programs; (2) the lack of potential controversy; and (3) the cost effectiveness of the
Program. However, Staff was concerned with the Company’s unilateral discretion to deny
participation in the Program, and how the Company would handle potential failures of its Load
Control Devices (“LCD”).
Staff reviewed the Company’s estimated costs for providing the Automatic Dispatch
Option and believed that the Program should remain cost-effective. The Company used the $51.42
per kilowatt-year cost-effectiveness threshold identified in its recent DR modification case, Case
No. IPC-E-21-32. The Company estimated participation would increase by 10 to 20 participants
with incremental costs ranging between $1,160 to $1,500 for each participant. Applying those
changes to the existing program, the Company predicted a cost-effectiveness margin of $189,000.
Staff concurred with the proposed Tariff language as filed; however, Staff was concerned
with the Company’s unlimited discretion to accept or deny participants and that the Tariff did not
provide constraints for denying a customer’s participation. Staff recommended the Company
document any instances when it denied a customer’s participation in the Program and the reasons
for the denial.
Staff agreed with granting the Company authority to waive the non-compliance penalty if
the LCD failed to communicate during an event. However, Staff was concerned that the failures
might not be resolved in a timely manner if adverse consequences were dismissible. To ensure the
ORDER NO. 35677 3
ongoing effectiveness of the Program, Staff recommended that the Company investigate when
failures occurred and that the Company document such failures, the nature of the problem(s), and
the efforts to remedy the problem.
COMPANY COMMENTS
The Company agreed with Staff’s recommendations and appreciated the opportunity to
alleviate Staff’s concerns. The Company reaffirmed that even though the Tariff language provided
Company discretion to deny participation in the Program, that discretion would continue to be
used in the best interest of all customers so that reliable load reduction during DR events was
achieved. The Company represented that application denials were a rare occurrence for any of its
DR programs.
As for Program application documentation, the Company represented that it had an existing
applicant documentation process in place for all three of its DR programs that noted whether an
applicant was accepted or denied. The Company stated that it would ensure the same
documentation practices were implemented for the Automatic Dispatch Option.
Finally, the Company represented that it already had LCD documentation and remediation
practices in place for its automated residential and irrigation DR programs and that it was
committed to implementing those practices for the Commercial & Industrial (“C&I”) Automatic
Dispatch Option as well.
COMMISSION FINDINGS AND DECISION
The Commission has jurisdiction over the Company’s Application and the issues in this
case under Title 61 of the Idaho Code including, Idaho Code §§ 61-501, -502, and -503. The
Commission is empowered to investigate rates, charges, rules, regulations, practices, and contracts
of all public utilities and to determine whether they are just, reasonable, preferential,
discriminatory, or in violation of any provisions of law, and to fix the same by order. Id.
Having reviewed the Application, the record, and all submitted materials, the Commission
finds it fair, just, and reasonable to approve the addition of the Automatic Dispatch Option to the
Company’s Flex Peak Program, and to approve the associated modifications to Schedule 82. The
Company is encouraged to ensure that the applications, performance, and maintenance of its DR
programs are thoroughly documented in accordance with its own policies and procedures, and in
consideration of the concerns expressed by Staff in its comments.
ORDER NO. 35677 4
ORDER
IT IS HEREBY ORDERED the Company’s Application requesting authority to modify
Schedule 82, Flex Peak Program, of Idaho Power’s I.P.U.C No. 29 Tariff No. 101 is approved as
filed.
THIS IS A FINAL ORDER. Any person interested in this Order may petition for
reconsideration within twenty-one (21) days of the service date upon this Order regarding any
matter decided in this Order. Within seven (7) days after any person has petitioned for
reconsideration, any other person may cross-petition for reconsideration. Idaho Code §§ 61-626
and 62-619.
DONE by Order of the Idaho Public Utilities Commission at Boise, Idaho this 3rd day of
February 2023.
ERIC ANDERSON, PRESIDENT
JOHN R. HAMMOND JR., COMMISSIONER
EDWARD LODGE, COMMISSIONER
ATTEST:
Jan Noriyuki
Commission Secretary
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