20230110Comments.pdf

CHRIS BURDIN
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE,IDAHO 83720-0074 ON
[phone]
IDAHO BAR NO.9810
Street Address for Express Mail:
11331 W CHINDEN BLVD,BLDG 8,SUITE 201-A
BOISE,ID 83714
Attorneyfor the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF IDAHO POWER )COMPANY'S APPLICATION FOR A )CASE NO.IPC-E-22-24
MODIFICATION TO ADD AN AUTOMATIC )DISPATCH OPTION TO THE COMPANY'S )COMMERCIAL &INDUSTRIAL DEMAND )COMMENTS OF THE
RESPONSE PROGRAM,SCHEDULE 82 )COMMISSION STAFF
Staff of the Idaho Public Utilities Commission ("Staff'),by and through its Attorney of
record,Chris Burdin,Deputy Attorney General,submits the followingcomments.
BACKGROUND
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 proposes to add a voluntaryAutomatic Dispatch
Option Program like that of the A/C Cool Credit and Irrigation Peak Rewards programs.
The Company seeks 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
STAFF COMMENTS 1 JANUARY 10,2023
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 manuallyreduce load when the
Company calls DR events.The Company represents that customers nominate on a weekly basis
the load they would reduce if an event was called,and their performance based on achieving
their nominated load reduction is factored into incentive payments.
The Company's proposed voluntaryAutomatic Dispatch Option for the Program involves
installinga 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 states
that when a DR load control event is called,the Company will continue to notify customers via
telephone,text,or email about four (4)hours before an event and will 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.
The Company asserts that because this method is already utilized in Idaho Power's other
two DR programs,the Company already has experience and familiarity with the technology,the
process,and the execution of an automatic option.
The Company states that the purpose of adding this option is 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 represents that this proposal does not impact the availabilityof the "Manual
Dispatch Option,"and current and potential customers will still be able to participate in the
Program manually,if preferred.
STAFF REVIEW
Staff reviewed the Company's Application and recommends the Commission grant the
Company authorization to implement the voluntarydispatch option for the Flex Peak Program.
Staff's conclusion is 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.
STAFF COMMENTS 2 JANUARY 10,2023
However,Staff is concerned with the Company's unilateral discretion to deny
participation in the program and how the Company will handle potential failures of its Load
Control Devices ("LCD").
Staff is confident in the Company's ability to institute an automatic dispatch option for
their Flex Peak Program.Staff notes that the three DR programs (AC Cool Credit,Flex Peak
Program,and Irrigation Peak Rewards Program)are well established and that the AC Cool
Credit and IrrigationPeak Rewards Program have already instituted an automatic dispatch
option.Application at 5.Also,Staff believes that customers are familiar with the idea of
automatic dispatch,so the potential for controversy is small,and the voluntarynature of the
program further reduces the potential for controversy.
Staff reviewed the Company's estimated costs for providing an automatic dispatch option
and believes that the Flex Peak Program should remain cost-effective.The Company used the
$51.42 per kilowatt-yearcost-effectiveness threshold identified in its recent DR modification
case,Case No.IPC-E-21-32.The Company estimates participation will increase by 10 to 20
participants with incremental costs ranging between $1,160 to $1,500 for each participant.
Applying these changes to the existing program,the Company predicts a cost-effectiveness
margin of $189,000 and expects the program to remain cost-effective.
The Company did not consider the cost impact for recovery of its LCD if a participant
drops out of the program.In its Response to Production Request No.2,the Company explains
that it intends to leave LCDs in place unless the customer requests its removal.This is the
Company's practice for its IrrigationPeak Rewards Program because it avoids the cost of
removal,and it mitigates future installation costs should the customer re-enroll later.The
Company estimates removal costs between $200 to $400 per workorder for a total of $2,000 per
year,which is not expected to have a significant impact on the Program's cost-effectiveness.
Given that the LCD costs between $160 to $500,Staff believes this approach is reasonable.
Staff concurs with the proposed Tariff language as filed;however,Staff 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.The Company's justification for
having unilateral discretion includes:the Company's ability to manage total Program capacity,
inability of a customer to attain the 20-kilowattminimum load reduction,inability to establish
dispatch communications to the site,or inability to remotely configure the electrical system.
STAFF COMMENTS 3 JANUARY 10,2023
Response to Production Request No.4.This Tariff language has been in place for all three DR
programs implemented prior to this Application,and it has not caused any issues thus far.Given
this reason,Staff concurs with the policy;however,Staff recommends the Company document
any instances when it denies a customer's participation in the DR program and the reasons for
the denial.
Staff concurs with granting the Company authorityto waive the non-compliance penalty
if the LCD fails to communicate during an event.However,Staff is concerned that the failures
may not be resolved in a timely manner if adverse consequences are dismissible.To ensure the
ongoing effectiveness of the Program,Staff recommends that the Company investigatewhen
failures occur and that the Company document such failures,the nature of the problem(s),and
the efforts to remedy the problem.
STAFF RECOMMENDATIONS
Staff recommends:
1.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.The Company document instances when a customer is denied participation in a
DR program,and instances when LCDs fail to communicate during an event.
Respectfully submitted this /day of January 2023.
Chris Burdin
Deputy AttorneyGeneral
Technical Staff:Matt Suess
Jason Talford
Laura Conilogue
i:umisc/comments/ipce22.24cbmsjjt1c comments
STAFF COMMENTS 4 JANUARY 10,2023
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 10th DAY OF JANUARY 2023,SERVED THE FOREGOING COMMENTS OF THE COMMISSION STAFF,IN CASE
NO.IPC-E-22-24,BY E-MAILING A COPY THEREOF,TO THE FOLLOWING:
MEGAN GOICOECHEA ALLEN CONNIE ASCHENBRENNER
LISA NORDSTROM ZACK THOMPSON
IDAHO POWER COMPANY IDAHO POWER COMPANY
PO BOX 70 PO BOX 70
BOISE ID 83707-0070 BOISE ID 83707-0070
E-MAIL:[e-mail] E-MAIL:[e-mail]
[e-mail] [e-mail]
[e-mail]
S CRE Y
CERTIFICATE OF SERVICE