20030314Supplemental Reply Comments.pdf

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John M. Eriksson
STOEL RIVES LLP
201 South Main Street, #1100
Salt Lake City, Utah 84111-4904
Telephone: [phone]
Facsimile: [phone]
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Mary S. Hobson (ISB #2142)
STOEL RIVES LLP
101 S. Capitol Blvd., Suite 1900
Boise, Idaho 83702-5958
Telephone: [phone]
Facsimile: [phone]
Attorneys for PacifiCorp
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION OF
PACIFICORP DBA UTAH POWER & LIGHT
COMPANY FOR APPROV AL OF AMENDED
ELECTRIC SERVICE SCHEDULE 72 -
IRRIGATION LOAD CONTROL CREDIT RIDER PROGRAM.
CASE NO. P AC-O3-
SUPPLEMENTAL REPLY
COMMENTS OF
ACIFICORP
PacifiCorp, doing business as Utah Power & Light Company ("PacifiCorp" or the
Company ), respectfully submits these Supplemental Reply Comments regarding the
Company s calculation ofthe level of credit to be given for interruption.
In its initial Reply Comments, PacifiCorp addressed the appropriateness of its
method of calculating the level of credits for interruption, responding to Staffs Comments
regarding the consideration of "lost revenues" in that method. Since filing those Reply
Comments, PacifiCorp has had further discussions with Staff and representatives of the Idaho
Irrigation Pumpers Association (the "Irrigators ). While PacifiCorp believes the concern with
P ACIFICORP'S SUPPLEMENTAL REPLY COMMENTS - 1
SaltLake-197532.1 0058802-00097
providing recovery oflost revenues is not applicable in this instance, PacifiCorp proposes herein
an alternative methodology for calculating the credits for the 2003 irrigation.
The Irrigators have indicated that load that would be interrupted pursuant to
Schedule 72 would actually be shifted to hours outside the scheduled load control periods.
course, there is value in shifting load out of the super-peak periods. The Company has analyzed
the value associated with shifting load from the super-peak periods to other times of the week.
As would be expected, the curtailment program would yield a high level of value if load is
shifted from the proposed curtailment hours to light load hours.
The Company believes that there should be additional study to determine if, and
to what extent, load shifting to other hours takes place as a result ofthe Schedule 72 curtailment
program. However, given the desire and need to implement the program for the 2003 irrigation
season as soon as possible, the Company proposes to provide the credits listed below, based on
an alternative methodology that recognizes value obtained by shifting load from super-peak to
light load hours, utilizing a comparison of super-peak market prices to light load hour market
prices. These revised credit amounts result in increases to the credits of 0% to 29%, compared to
the credits initially proposed by the Company.
June: $1.54/kW-mo (28% increase)
July: $2.06/kw-mo (11 % increase)
August: $2.25/kW-mo (no change)
September: $1.26/kW-mo (29% increase)
The calculation of these proposed credits is shown in the attached Exhibit 1.
The Company also proposes to study the extent and effect of load shifting resulting from
implementation of the curtailment program, and to present the results of the study to the
PACIFICORP'S SUPPLEMENTAL REPLY COMMENTS - 2
SaItLake-197532.1 0058802-00097
Commission and the Irrigators with the Company s proposal for valuing curtailment credits for
the 2004 irrigation season.
The proposed credits are different for each month to reflect the varying costs of
power, and hence, value of curtailment, in each of the months. While administering the program
would be easier if there were a single average curtailment credit, the Company believes that
providing the different credits according to the differing value is necessary to insure that if
irrigators exit the program early, other customers do not bear the burden of having paid more
than the value provided by those irrigators that leave the program.
The alternative methodology utilized in determining the revised proposed credits
is based on the Company assuming that some load will indeed shift from the curtailment hours to
light load hours. In valuing this load shift, PacifiCorp implemented a 70% uncertainty factor in
recognition of uncertainties with respect to (a) the amount ofload that actually is shifted, (b) the
hours of the day that load is actually shifted to, (c) the level ofload control equipment failure, (d)
unexpected differences between estimated load and actual load, ( e) failure of customers to
curtail, and (f) customer termination from the program for previously failing to curtail. Because
of all these uncertainties, the Company believes the value of the presumed load shift must be
discounted, and that the 70% factor applied by the Company is appropriate.
PacifiCorp submits the proposed credits stated above, and the alternative
methodology used to determine those credits, in lieu of the credits and methodology previously
proposed. The alternative methodology does not involve the use of "lost revenues" in
determining program value and provides that the anticipated program value, after consideration
of certain program uncertainties, will be passed on to the participating customers via a pre-
determined credit.
PACIFICORP'S SUPPLEMENTAL REPLY COMMENTS - 3
SaltLake-197532.1 0058802-00097
WHEREFORE, PacifiCorp respectfully requests that the Commission approve the
proposed Schedule 72, with the curtailment credits stated above to be used for the 2003 irrigation
season.
DATED this (:3 1"1 day of March, 2003.
~oo M. Eriksson
Mary S. Hobsom
Stoel Rives LLP
Of Attorneys for PacifiCorp
PACIFICORP'S SUPPLEMENTALREPLYCOMMENTS-
SaltLake-197532.10058802-00097
CERTIFICATE OF SERVICE
I hereby certify that on this ! -3
t'"day of March, 2003, I caused to be served, via
facsimile, a true and correct copy of the foregoing Supplemental Reply Comments of
PacifiCorp to the following:
Scott Woodbury
Deputy Attorney General
Idaho Public Utilities Commission
472 W. Washington
Boise, Idaho 83720-0074
Eric L. Olsen
Racine, Olson, Nye , Budge & Bailey
PO. Box 1391
Pocatello, ill 83204-1391
P ACIFICORP'S SUPPLEMENTAL REPLY COMMENTS - 5
SaltLake-197532.1 0058802-00097
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