20240215Reply Comments.pdf

MEGAN GOICOECHEA ALLEN
Corporate Counsel
[e-mail]

February 15, 2024

Commission Secretary
Idaho Public Utilities Commission
11331 W. Chinden Boulevard
Building 8, Suite 201-A
Boise, Idaho 83714

Re: Case No. IPC-E-23-24
Application for Modifications to the Company’s Commercial & Industrial
Demand Response Program, Schedule 82

Dear Commission Secretary:

Attached for electronic filing is Idaho Power Company’s Reply Comments in the
above-entitled matter.

If you have any questions about the attached documents, please do not hesitate
to contact me.

Sincerely,

Megan Goicoechea Allen
MGA:sg
Enclosures
RECEIVED
Thursday February 15, 2024 4:27PM
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
MODIFICATIONS TO THE COMPANY’S
COMMERCIAL & INDUSTRIAL DEMAND
RESPONSE PROGRAM, SCHEDULE 82.
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CASE NO. IPC-E-23-24

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. 36049, respectfully submits the following Reply
Comments in response to Comments filed by the Commission Staff (“Staff”) on January
25, 2024.
I. REPLY COMMENTS
Idaho Power appreciates Staff’s thorough review and assessment of the
Company’s proposed modifications to its Commercial & Industrial (“C&I”) Demand
Response (“DR”) Program, Schedule 82 (“Schedule 82”, “Flex Peak Program”, or
IDAHO POWER COMPANY’S REPLY COMMENTS - 2
“Program”). Staff’s Comments include six recommendations, which the Company will
address in these Reply Comments in turn as follows.
1. “Staff recommends that the Commission approve the Company’s proposal to
modify the incentive payment structure.”1
The Company agrees with Staff and requests the Commission approve Idaho
Power’s proposal to modify the incentive payment structure of the Flex Peak Program.
Idaho Power appreciates Staff’s feedback, collaboration, and thorough review of the
Company’s proposal.
2. “Staff recommends that the Commission approve the Company’s proposal to
add a performance waiver for participants with the automatic dispatch option.”2
The Company agrees with Staff and requests the Commission approve Idaho
Power’s proposal to add a performance waiver for the Flex Peak Program’s automatic
dispatch option participants.
3. “Staff Supports the Company’s proposal to adjust the definition of the “day-of”
load adjustment, however, Staff recommends that the Company include
additional language in the tariff clarifying how the Company might modify the
day-of adjustment in those situations.”3
The Company appreciates Staff’s support of the Company’s proposal to amend
the definition of the “Day of” Load Adjustment in Schedule 82 to include considerations
for planned or unplanned outages during a day when a Load Control Event is called,
which is necessary to measure a participant’s actual performance during the event. After

1 Staff Comments at 8.
2 Id.
3 Id.
IDAHO POWER COMPANY’S REPLY COMMENTS - 3
reviewing the Commission Staff’s comments, the Company consulted with Staff and
proposes the following language be incorporated into Schedule 82 (new language is
underlined):
“Day of” Load Adjustment. The difference between the Original Baseline kW
and the actual metered kW during the hour prior to the Participant receiving
notification of an event. Scalar values will be calculated by dividing the
Original Baseline kW for each Load Control Event hour by the Original
Baseline kW of the hour preceding the event notification time. The scalars
are multiplied by the actual event day kW for the hour preceding the event
notification time to create the Adjusted Baseline kW from which load
reduction is measured. The Adjusted Baseline kW for each hour cannot
exceed the maximum kW amount for any hour from the Highest Energy
Usage Days or the hours during the event day prior to event notification.
The Company may adjust the Participant’s “Day of” Load Adjustment only
if a planned or unplanned outage occurs during the hour prior to the
Participant receiving notification of a Load Control Event. If an outage
extends to the hours of the Load Control Event, the Company may remove
that event from the Participant’s Average Season Performance Percentage.

The proposed language clarifies that the outage must occur during the hour prior
to the participant receiving notification of a Load Control Event and clarifies that if an
outage extends to the hours of the DR event, the Company may remove that event from
the participant’s Average Season Performance Percentage. This language is consistent
with the intent of the Company’s proposal such that the participant is neither penalized
nor compensated for non-performance that was out of the participant’s control due to an
outage.
If the Commission ultimately adopts the Company’s recommendation to allow for
adjustments to the “Day of” Load Adjustment in the event of outages, it respectfully
requests the Commission direct the Company to include the revised language with its
compliance filing.

IDAHO POWER COMPANY’S REPLY COMMENTS - 4
4. “Staff recommends that the Commission approve the Company’s proposal to
implement an advance notification option for participants capable of large
nominations as a pilot program […].”4
The Company appreciates and agrees with Staff’s recommendation for approval
of the advance notification option but does not believe it is necessary to implement it as
a pilot program. Because the advance notification option proposal was designed, and is
only intended, to have a small number of participants that qualify, Idaho Power believes
that offering initially as a pilot program creates an unnecessary administrative step.
Notably, as this and other recent cases (e.g., IPC-E-21-32 and IPC-E-22-24)
illustrate, the Company evaluates all Flex Peak Program parameters on an ongoing basis
to ensure the Program is cost-effective and administratively efficient. Essentially, all
elements of the Program are already frequently reviewed and adjusted as appropriate,
such that it is not necessary to establish a pilot program to fulfill these objectives.
Moreover, the Company is concerned that creating a pilot program for a specific Program
parameter, while well intentioned, may suggest to customers that the other Program
parameters are fixed and not likely to change. Currently, all Flex Peak Program
participants receive an auto-enrollment packet before every DR season that contains their
participating sites, nomination levels, and detailed information on applicable Program
changes – that is, each season, a customer decides whether to participate in the
upcoming season based on the parameters in place in advance of the upcoming season.
The timing of the cases referenced by the Company have been such that Program
parameters are set and established in advance of that recruitment window, so that the

4 Staff Comments at 8.
IDAHO POWER COMPANY’S REPLY COMMENTS - 5
Company can educate customers and enable them to make informed decisions based on
then existing circumstances.
Additionally, it is important to consider the limited scope of the advanced
notification option. While the Company is aware that Staff issued discovery responses to
this end, it believes some additional detail would provide useful context. More specifically,
Staff asked, in its First Production Request to the Company, for a count of participants
that can nominate 3 megawatts (“MW”) or more of load reduction, to which the Company
responded that there were currently 24 participants in the Flex Peak Program with Basic
Load Capacity (“BLC”) values of greater than 3 MW.5 The Company explained in its
response, it calculates BLC as the average of the two highest monthly billing demands
over the past 12 months, and based on that specification, 24 current participants have
the “potential” to nominate more than 3 MW. However, only 1 current participant has
“actually” nominated more than 3 MW to date. Considering these circumstances, the
Company does not anticipate there will be many customers participating in this option.
Though the Company does not believe it is necessary to implement the advance
notification option as a “pilot option” within the Program for the reasons explained above,
it proposes, as an alternative, that it report the advance notification option participation
and performance results, broken out as separate line items in its Demand-Side
Management (“DSM”) Annual Report going forward. Idaho Power already includes event
and season-level metrics for the Flex Peak Program in its DSM Annual Report and can
reasonably add an additional breakout showing the advance notification option’s
contributions to the overall Flex Peak Program. This additional breakout will ensure Staff

5 See Idaho Power’s Response to Staff’s Request for Production No. 5.
IDAHO POWER COMPANY’S REPLY COMMENTS - 6
and the Commission are able to review the participation and performance levels of the
advance notification option on an annual basis.
The Company requests the Commission approve the advance notification option,
without pilot status, and issue an order requiring the Company to report the advance
notification option’s participation and performance metrics as separate line items in the
DSM Annual Report filed with the Commission every March.
5. “Staff recommends that the Company continue to monitor the actual demand
reduction of its Flex Peak program and work with Staff and stakeholders to
evaluate the cost-effectiveness of its DR programs using actual participant
performance rather than nameplate capacity.”6
The Company agrees with the underlying intent of this recommendation insofar as
it reflects Staff’s desire to ensure that the Company’s DR programs are appropriately
valued; although the Company believes there should be further discussion regarding the
best method(s) for achieving this objective. To this end, Idaho Power is committed to
continuing to work with Staff and stakeholders to evaluate the cost-effectiveness of its DR
programs. Through the Company’s ongoing evaluation conducted to date utilizing the
cost-effectiveness methodology that was approved by the Commission in Order No.
35336 in Case No. IPC-E-21-32, Idaho Power has identified several different methods
that could potentially be used to evaluate DR cost-effectiveness moving forward. Idaho
Power welcomes future engagement with Staff and stakeholders on this topic through
Energy Efficiency Advisory Group meetings and/or DR sub-committee meetings where

6 Staff Comments at 9.
IDAHO POWER COMPANY’S REPLY COMMENTS - 7
all potential cost-effectiveness evaluation methodologies can be reviewed in a
collaborative manner.
Considering the ever-evolving needs of the system, the Company anticipates
changes to all three of its DR programs may be necessary ahead of the 2025 DR season.
In the event the Company determines that changes to the DR programs are needed,
having an avoided cost calculation recommendation that was collaboratively developed
by parties would help to ensure a proposal that balances the costs and benefits of DR is
brought before the Commission for its review.
6. “Staff recommends that the Company submit a compliance filing including
language on Staff’s recommended pilot program, if accepted by the
Commission, additional language on the “day-of” load adjustment, corrected
language on participant nominations, and other changes as needed to reflect
the contents of the Commission’s order.”7
The Company agrees with Staff, except as otherwise noted above, and will submit
a compliance filing that includes all changes approved by the Commission in its final
order.
II. CONCLUSION
Idaho Power values Staff’s thorough review and recommendations related to the
Company’s proposed modifications to Schedule 82 and appreciates its support for the
proposed modification to the Flex Peak Program’s incentive payment structure and the
addition of a performance wavier under the automatic dispatch option, as noted in Staff’s
recommendations 1 and 2. As set forth in its Application, the Company desires to

7 Staff Comments at 9.
IDAHO POWER COMPANY’S REPLY COMMENTS - 8
implement updates to the Flex Peak Program for the 2024 demand response season,
which begins on June 15, 2024, and believes a Commission order received by April 15,
2024, would best position the Company to implement and market the proposed changes
and provide it with sufficient time to complete a successful rollout of the modified incentive
payment structure and other changes in advance of the 2024 DR season.
Accordingly, Idaho Power requests that the Commission issue an Order by April
15, 2024, approving updates to the Flex Peak Program for the 2024 DR season as
proposed by the Company subject to the adjustments to the “Day of” Load Adjustment
definition based on Staff’s recommendation item 3, and directing the Company make a
tariff compliance filing reflecting the associated modifications to Schedule 82 effective
coincident with the Order. Additionally, in consideration of Staff’s recommendation items
4 and 5, the Company requests that the Commission direct the Company to report the
advance notification option’s participation and performance metrics as separate line items
in its DSM Annual Report, without pilot status, and affirm that the Company, Staff, and
stakeholders should collaboratively consider other potential cost-effectiveness evaluation
methodologies as part of the ongoing efforts to evaluate the cost-effectiveness of the
Company’s DR programs.
DATED at Boise, Idaho, this 15th day of February 2024.

________________________________
MEGAN GOICOECHEA ALLEN
Attorney for Idaho Power Company
IDAHO POWER COMPANY’S REPLY COMMENTS - 9
CERTIFICATE OF SERVICE

I HEREBY CERTIFY that on the 15th day of February 2024, I served a true and
correct Idaho Power Company’s Reply Comments upon the following named parties by
the method indicated below, and addressed to the following:

Commission Staff
Adam Triplett
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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