20030306Comments.pdf

SCOTT WOODBURY
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
BAR NO. 1895
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Street Address for Express Mail:
472 W. WASHINGTON
BOISE, IDAHO 83702-5983
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION OF
ACIFICORP DBA UTAH POWER & LIGHT
COMP ANY FOR APPROVAL OF AMENDED
ELECTRIC SERVICE SCHEDULE 72
IRRIGATION LOAD CONTROL CREDIT RIDER PROGRAM.
CASE NO. P AC-O3-
COMMENTS OF THE
COMMISSION STAFF
COMES NOW the Staff of the Idaho Public Utilities Commission, by and through its
Attorney of record, Scott Woodbury, Deputy Attorney General, and in response to the Notice of
Application, Notice of Modified Procedure and Notice of Comment /Protest Deadline issued on
February 13, 2003, submits the following comments.
BACKGROUND
On January 31 2003, PacifiCorp dba Utah Power & Light Company (PacifiCorp;
Company) filed an Application with the Idaho Public Utilities Commission (Commission)
requesting approval of a proposed amended electric service Schedule 72 - Irrigation Load
Control Credit Rider program. The Company s filing is Attachment A to these comments.
PacifiCorp contends that its filing complies with the Company s commitment to irrigators and
Commission Order No. 29034 wherein the Company agreed to work with irrigators to develop
an optional load control program beginning with the 2003 irrigation season. (Case No.
STAFF COMMENTS MARCH 6, 2003
PAC-02-, O.N. 29034 at 18) Under the proposed tariff schedule, customers opting to
participate in the load control program will receive credits to their bills during three and one-half
months of the irrigation season. Each participating customer would be interrupted during two
six-hour blocks each week. The interruption would be 2:00 PM to 8:00 PM on two days of the
Company s choosing, except, the Company would not interrupt on Sundays. The Commission
Staff (Staff) understands that the program was developed with irrigator input and Staff does not
oppose the Company s plan for interruption.
IMPLEMENTATION
The time for review and implementation of Schedule 72 for 2003 is very short because
irrigators will soon be required to make commitments for the coming season. The Company
Application, Tariff Sheet No. 72.2 contains an implementation schedule for 2003 , which begins
with a customer Notification of Credit "no later than February 28th " To allow for processing of
the Application the Commission suspended the proposed effective date, which necessitates a new
implementation schedule. It is expected that a final order will not be issued until almost the
middle of March, so action dates such as the February 28th - Notification of Credit, the March
14th - Customer Intent to Participate, the March 31 st - Notification of Load Control Schedule and
the April 11 th - Load Control Service Agreement trigger dates will need to be set back. Staff
proposes, with Company agreement, to tie the trigger dates to the date the final order is issued.
The proposed changes to the "Schedule" portion of Tariff Sheet 72.2 are Attachment B to these
comments. For clarity calendar dates should be substituted when the final order is issued. Staff
recognizes that delay in establishing the program may cause problems for irrigators considering
participation. However, Staff believes some opportunity for review is critical to assure that the
program is properly implemented.
LANGUAGE
Staff has reviewed proposed Schedule 72 and has asked the Company questions
concerning the design of the program, the obligations of the parties and the calculation of the
credit. As a result of that process the Company and Staff agree as follows:
The Load Control Service Agreement will include typical costs that the customer may
incur for early termination.
Early termination costs will not include costs for replacement power.
STAFF COMMENTS MARCH 6, 2003
The Company will delete the language from Special Condition No., Metering, which
states "Participation is subject to meter availability.
The following language will be added to Special Condition No.5. "PacifiCorp reserves
the right to determine if the participating customer is in violation of Special Condition 5
Load Shifting. Violation of Special Condition No.5 shall result in Early Termination
under the terms of Special Condition No., forfeiture of the Load Control Service Credit
for the current month, and removal from the program for the remainder of the Irrigation
Season. "
The following additional Special Condition will be added. "9. Free Riders . Customers
may not participate in this program with accounts and meters that would not have used
power during the Irrigation Season irrespective of participation in the program.
PacifiCorp reserves the right to determine if the participating customer is in violation of
Special Condition 9 , Free Riders. Violation of Special Condition No.9 shall result in
Early Termination under terms of Special Condition No., forfeiture of the Load Control
Service Credit for the current month, and removal from the program for the remainder of
the Irrigation Season.
Staff points out that the Load Control Service Agreement (LCSA) requested from the
Company, is, at the time of this filing, still being developed and cannot be reviewed except for
the representations that the Company has made concerning what it will contain. With these
changes Staffis satisfied with program design, terminology and the obligations of the parties.
LOAD CONTROL VALUE
A very important aspect of the Company s filing is the calculation of the value of load
control or interruption. Staff has serious concerns with the Company s calculation of the value
of interruption because it includes "lost revenue." PacifiCorp s response to production request
question 2 (see Attachment C) describes the method used to determine the value. Essentially the
Company s proposal is to credit customers who agree to be interrupted with 80 percent of the
difference in the value of the energy at market and the value of the energy that would otherwise
be sold to the irrigators at Schedule 10 irrigation rates. The method employed by the Company
in determining the value of the credit deducts, what amounts to
, "
lost revenue" from the market
value of the interrupted energy. The Commission in recent orders has not accepted lost revenue
STAFF COMMENTS MARCH 6, 2003
as a legitimate allowable cost that can be recovered from ratepayers. In its findings in Case No.
P AC- E-O 1-16 concerning a new contract for Monsanto the Commission said:
We find it reasonable to eliminate the "lost revenue" adjustment proposed
by Pacificorp in its rebuttal. If the Company wishes to pursue the lost
revenue issue, it is more appropriately considered in a general rate case.
(Order No. 29157 at 11)
In Case No. IPC-01-34 concerning Idaho Power s irrigation load reduction (buy-back)
program the Commission said:
In its Application Idaho Power requests that the Commission include
reduced revenue (lost revenue J costs that it claims to have incurred as a
result of the Irrigation Load Reduction Program in the 2002/2003 PCA
year. Idaho Power and Staff quantified the amount that is alleged to have
accrued through September 2001 at approximately $9 783 625. We
decline to include these costs in the 2002/2003 PCA year.
(Order No. 28992 at 7)
On reconsideration in that same case the Commission said:
The Commission finds that lost revenue is not a recoverable "expense" to
be recovered from ratepayers like the direct costs from this program (i.
the payments to irrigators). In general, the Commission finds that rates
should accurately reflect the actual costs incurred to provide service.
Given the unique context that caused this Program to be implemented, we
find that lost revenue does not constitute an actual cost of providing
service that should be borne by ratepayers.
(Order No. 29103 at 9)
That Order goes on to conclude:
Based on the foregoing, we find that our decision in Order No. 28992 to
deny Idaho Power the authorization to recover lost revenue from operation
of the Irrigation Load Reduction Program during 2001 was not
unreasonable, unlawful, erroneous or unduly discriminatory. We also find
that Order No. 28992 conforms with the facts of record and/or applicable
law. Furthermore, the Commission does not find that the denial of the
recovery of lost revenue results in confiscatory rates. The Commission
also finds that Order No. 28992 is not an unlawful collateral attack on
Order No. 28699. Finally, we decline to modify our Order to provide that
Idaho Power is entitled to recover all "costs" that it would incur as a result
of the implementation of any demand-side management program.
(Order No. 29103 at 12 13)
STAFF COMMENTS MARCH 6, 2003
In order to be consistent with previous Commission findings, Staff proposes that the
Company s method of valuing load control be adjusted to exclude lost revenue considerations. It
appears that the dollar amount of the credit would then become 80 percent of the market value of
the interrupted energy.
DESIGN OF THE LOAD CONTROL CREDIT
PacifiCorp s response to production request question I (see Attachment C) contains the
proposed load control credits for 2003. Each month has a Monthly Participation Credit and a
kWh Credit. The kWh Credit is $0.00 for all months and the Monthly Participation Credit varies
from $0.98 to $2.25 per kW-Month when lost revenues are included in the calculation.
The Company proposed Schedule 27 rate rider offsets the Schedule 10 demand charge
with a credit; then, if a portion of the load control credit remains after the demand charge is
completely offset, Schedule 10 energy rates are offset with an energy based rate rider credit. The
design of the 2003 monthly credits produces offsets to the irrigation demand charges as
previously discussed, but is not large enough in any month to completely offset the demand
charge and produce an energy credit.
This methodology is acceptable to Staff. Staff believes that the monthly demand and
energy rate credits will be substantially larger when they are recalculated without lost revenue.
RECOMMENDATIONS
Staff recommends that the Commission approve the Irrigation Load Control Program for
2003 with the changes proposed in these comments. The only unresolved difference between
Staff and Company is the lost revenue issue. The exclusion of lost revenues from the credit
calculation should result in much higher Schedule 72 credits that should encourage additional
irrigator participation. Due to the short time available for review, the Staff has had no discussion
with the irrigators concerning the proposed changes in the program.
Staff further recommends that at the end of the Schedule 72 program in 2003, the
Company prepare a detailed report on the program and file it with the Commission. The filing
should contain the number of irrigation customers who: 1) were eligible to participate in the
program; 2) filed a letter of intent to participate; 3) entered into a Load Control Service
Agreement; 4) participated in the program for the full three and one-half months, and 5) are not
eligible to participate next year. The report should also include the total dollar amount of credits
STAFF COMMENTS MARCH 6, 2003
provided under the program identified by month. The filing should include any proposed
changes or recommendations to improve the program that the Company wishes to make as well
as any other information that the Company wishes to present. This filing should be made no
later than December I , 2003. The Commission should then allow comments and
recommendations from other interested parties prior to any reauthorization of the program in
2004. The reason for this recommendation springs from the extremely short review period
available in this case and the potential to improve the program with a year s experience.
Respectively submitted this 11.~6 day of March 2003.
00 bury
Deputy Attorney General
Technical Staff: Dave Schunke
Keith Hessing
S W :jo:i:umisc/comments/paceO3 .3swdeskh
STAFF COMMENTS MARCH 6, 2003
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January 31, 2003 NEW CASE
Idaho Public Utilities Commission
472 West Washington
Boise, ill 83702-5983
jJA -E-o ~-tJ..3Attention; Jean D. Jewell
Commission Secretary
Re:Advice No. 03-
Schedule 72 - Irrigation Load Control Credit Rider
PacifiCorp Cd.a. Utah Power & Light Company) hereby submits for electronic filing a copy of the
following tariffs with a proposed effective date of March 3 2003.
Seventeenth Revision of Sheet No. B-
First Revision of Sheet No. 72.
First Revision of Sheet No. 72.
Second Revision of Sheet No. 72.3
Original Sheet No. 72.4
Schedule 72
Schedule 72
Schedule 72
Schedule 72
Table of Contents
Irrigation Load Control Credit Rider
Irrigation Load Control Credit Rider
. Irrigation Load Control Credit Rider
Irrigation Load Control Credit Rider
The purpose of this filing is to comply with the Company s commitment and Commission Order No.
29034 wherein the Company agreed to work with irrigators to develop an optional load control program
beginning with the 2003 irrigation season. The Company committed to file such a program with the
Commission no later than January 31 , 2003.
On December 5, 2002 and JanuaI)' 17 2003 the Company met with representatives of the Idaho Irrigation
Pumpers Association and the irrigation customer class to explain the Company s proposed tariff and to
solicit comments and suggestions from the impacted customers.
Under the proposed tariff schedule, customers opting to participate in the program will receive credits
during the irrigation season for the Company s ability to interrupt a designated amount of the customer
load. The Company will determine the value of the credits each year and advise customers of those
values. This approach is similar to that taken in Schedule 71, the Energy Exch~ge Program Rider
although the value of the credits will be fixed for the duration of the irrigation season.
Attachment A
Case No. PAC-03-
Staff Comments
03/06/03 Page 1 of
Idaho Public Utilities Commission
Advice No. 03-
January 31 , 2003
Page 2
In response to comments and concerns expressed by irrigation customers the Company modified its
original proposed tariff in the following areas:
The Load Control Service Credit was broken into two elements (a Fixed Monthly Participation Credit
and a KWh credit) to accommodate concern that a single element credit may not be capable of
delivering a credit large enough to attract significant participation in the program. For example, a
demand credit could be equal to the Customer s present Schedule 10 demand charge and still not be
high enough to encourage participation.
Load control events were limited to two events of 6 hours duration each per week in response to
concerns that the Company s original proposal of three load control events of 4 hours duration per
week would place an undue burden on potential participants.
The six hour load curtailment block was shifted to end earlier in the evening to accommodate
comments by the irrigation customers that they needed as much time as possible to reset their
irrigation systems following the curtailment.
Sunday was removed as a curtailment day in response to customers' indications that resetting
irrigation systems after a curtailment on Sunday presented planning problems related to the
availability of employees.
While it was not possible to respond to all the suggestions and concerns expressed by the irrigation
customers, the Company attempted to respond as positively as possible without diminishing the value of
the program.
It is respectfully requested that all formal correspondence and staff requests regarding this matter be
addressed to:
Bye-mail (preferred)to:
By regular mail to:
datarequ est~pacifi corp . com
Data Request Response Center
PacifiCorp
825 NE Multnomah, Suite 800
Portland, Oregon, 97232
[phone]By fax to:
Informal questions should be direCted to Bob Lively [phone].
Sincerely,
DD~v LlwJ
D. Douglas Larson
Vice President, Regulation
Enclosures
Attachment A
Case No. PAC-03-
Staff Comments
03/06/03 Page 2 of
utah
gJY!r
C. No. 28
Seventeenth Revised Sheet No. B.
Cancels Sixteenth Revised Sheet No. B.
ELECTRIC SERVICE SCHEDULES - Continued
ScheduleNo. Class of Service23 General Service - Small Power
Sheet
No.
23.1 - 23.3
23A
35A
120
122
300
400
General Service - Small Power (Residential and Farm)23A.l - 23Ao4
Interruptible Power Service 24.1- 24.
Pacific Northwest Electric Power Planning and
Conservation Act - Residential and Farm
Kilowatt-Hour Credit
34.1 - 34.
Optional Time-of-Day General Service - Distribution
Voltage
35.1 - 35.
Optional Time-of-pay General Service - Distribution Voltage (Farm)35A.l -35Ao4
Optional Time of Day Residential Service 36.1 - 36.
Energy Exchange Pilot Program 71.1 - 71.5
Irrigation Load Control Credit Rider 72.1 - 72.
Power Cost Adjustment
Rate Mitigation Adjustment
Commercial Energy Services - Optional to
Qualifying Customers
120.1 - 120.
Commercial Energy Services - Optional to
Qualifying Customers
122.1 - 122.
Regulation Charges 300.1 - 30004
Schedule numbers not listed are not currently used.
Special Contracts 400.1 - 400.
Submitted Under Advice Letter No. 03-
ISSUED: January 31 , 2003 EFFECTIVE: March 3 , 2003
Attachment A
Case No. PAC-03-
Staff Comments
03/06/03 Page 3 of
ulah
gJY!r
I.P.C. No. 28
First Revision of Sheet No. 72.
Canceling Original Sheet No 72.
UTAH POWER & LIGHT COMPANY
ELECTRIC SERVICE SCHEDULE NO 72
STATE OF IDAHO
Irrigation Load Control Credit Rider
PURPOSE: This optional tariff allows Customers to participate in pre-scheduled controlled service
inteITUptions in exchange for a Load Control Service Credit (LCSe).
APPLICABLE: To qualifying Customers served on Schedule 10. Prior to participation, and in
order to qualify under this Schedule, customers must execute a Load Control Service Agreement with the
Company.
IRRIGATION SEASON: This rider is applicable only during the Irrigation Season from June 1 to
September 15 each year.
LOAD CONTROL SERVICE CREDIT: The LCSC shall be applied to the participant's monthly
billing. The LCSC shall be applied in addition to the Customer s other monthly electric service charges.
The LCSC is composed of a Fixed Monthly Participation Credit plus a KWh Credit paid for the hours over
which a load control event occurs. In any year, the Company may set either the fixed monthly participation
credit or the kWh credit at $0.00.
BILLING: The Load Control Service Credit shall be computed monthly by multiplying the Fixed
Monthly Participation Credit times the Load Control kW, plus the KWh Credit times all Load Control kWh.
Load Control kWh shall equal Load Control kW times total number of load control hours in the month.
The Monthly Participation Credit and the kWh Credit shall remain fixed throughout the irrigation season
each year.
(Continued)
Submitted Under Advice Letter No. 03-
ISSUED: January 31, 2003 EFFECTIVE: March 3 , 2003
Attachment A
Case No. PAC-03-
Staff Comments
03/06/03 Page 4 of
DlabR!r"
C. No. 28
First Revision of Sheet No. 72.
Canceling Original Sheet No 72.
ELECTRIC SERVICE SCHEDULE NO 72 - ContinuedSCHEDULE:
Notification of Credit: Commencing in 2004 the Company will determine the Fixed Monthly
Participation Credit and the kWh Credit and shall provide notification of the LCSC to Schedule 10
, customers by January 15th of each calendar year. In 2003, notification of the LCSC shall occur no later
than February 28
Customer Intent to Participate: Customers desiring to participate in this load control program for
the upcoming Irrigation Season shall submit Intent to Participate notification to the Company by February
15th of each calendar year commencing in 2004. In 2003, customers shall submit Intent to Participate
notification to the Company by March 14 Customers failing to execute a Load Control Service
Agreement after submitting an Intent to Participate notification shall be ineligible to participate in the
program the following year.
Notification of Load Control Schedule: The Company will provide the participating Customers
the scheduled hours for load control during the Irrigation Season by March 1 st of each calendar year
commencing in 2004. In 2003, the Company will provide participating Customers the scheduled hours for
load control during the Irrigation Season by March 31st. Subject to ' the limitations described in the Load
Control Conditions below, the Company shall have the right to establish at its sole discretion the scheduled
load control hours for each participating customer, based on what the Company deems most beneficial to its
operations. The scheduled load control hours shall be fixed through the Irrigation Season each year in the
Load Control Service Agreement.
Load Control Service Agreement: Commencing in 2004, customers desiring to participate in this
load control program shall execute a Load Control Service Agreement with the Company by March 31st of
each calendar year. In 2003, customers shall execute a Load Control Service Agreement with the Company
by April 11 th
LOAD CONTROL CONDITIONS: The Company shall have the right to implement a load
control event for participating customers during the hours 2PM to 8PM Mountain Daylight Savings Time.
Duration of the load control event can be no more than six (6) continuous hours. Allowable days for load
control shall be each Monday through Saturday. No more than two (2) load control events per participating
customer per week shall be allowed. Maximum number of hours of load control per participating customer
is twelve (12) hours per week. No more than one load control event per participating customer may occur in
one day.
(Continued)
Submitted Under Advice Letter No. 03-
ISSUED: January 31 , 2003 EFFECTIVE: March 3, 2003
Attachment A
Case No. PAC-03-
Staff Comments
03/06/03 Page 5 of
ulah
H!r Ill"
I.P.C. No. 28
Second Revision of Sheet No. 72.
Canceling First Revision of Sheet No. 72.
ELECTRIC SERVICE SCHEDULE NO 72 - Continued
LOAD CONTROL SERVICE AGREEMENT: The Customer and Company will execute an
agreement for irrigation load control participation. The agreement shall specify the Load Control kW
amount that the customer shall curtail during a load control event. The agreement shall also specify the cost
of timers or other load control devices required to achieve' scheduled load control events. Participating
customers shall sign a written agreement for a term of one year. Except as provided in this Schedule
termination of the agreement may only occur on the annual expiration date of the agreement. Participating
customers are required to execute a Load Control Service Agreement annually.
SPECIAL CONDITIONS:
1. Metenng.The Customer must have a meter provided by the Company, which is capable of
recording usage intervals no less than 15 minutes. Participation is subject to meter availability.
2. Specified Load Control kW. The Load Control kW amount for each month of the Irrigation
Season shall be the average of the past three (3) years (or as available history) kW demand for
each month for the specific pump installation.
3. Outages. Uncontrolled outages or other types of interruptions do not quality for payment underthis tariff.
4. Liability. The Company is not responsible for any consequences to the participating Customer
that result from a Load Control Event or the failure of load control equipment.
5. Load Shifting.Customers participating in this program may not shift irrigation load to other
facilities served by the Company or purchase replacement production from another facility
served by the Company.
6. Failure to Interrupt During a Load Control Event.A Customer must participate in each
scheduled load control event during the irrigation season, except to the extent unable to due to
mechanical failure or malfunction of the load control device. PacifiCorp reserves the right to
determine if load control devices were intentionally damaged to limit load control. Failure to
participate in scheduled load curtailment shall result in termination of the load control service
agreement, forfeiture of the Load Control Service Credit for the CUITent month and immediate
removal from the program for the remainder of the Inigation Season.
(Continued)
Submitted Under Advice Letter No. 03-
ISSUED: January 31 2003 EFFECTIVE: March 3, 2003
Attachment A
Case No. PAC-03-
Staff Comments
03/06/03 Page 6 of
utah
H gJPJ!J1
I.P.c. No. 28 Original Sheet No 72.4
ELECTRIC SERVICE SCHEDULE NO 72 - Continued
SPECIAL CONDITIONS: (Continued)
7. Early Termination. If the Customer is terminated from this program, the Customer shan be
responsible for reimbursing the Company for costs associated with participation in the program.
Such costs include, but are not limited to, labor costs associated with enrolling the Customer in
the program, investigating intentional damage to load control devices, and removing the
customer from the program.
8. Cost of Control Devices.The participating Customer shall pay the cost of timers or other load
control devices and associated installation costs required to achieve scheduled load control
events.
, ELECTRIC SERVICE REGULATIONS: Service under this Schedule will be in accordance with
, the tenns of the Electric Service Agreement between the 'Customer and the Company. The Electric Service
Regulations of the Company on file with and approved by the Idaho Public Utilities Commission, including
future applicable amendments, will be considered as forming a part of and incorporated in said Agreement.
Submitted Under Advice Letter No. 03-
ISSUED: January 31, 2003 EFFECTIVE: March 3, 2003
Attachment A
Case No. PAC-03-
Staff Comments
03/06/03 Page 7 of
SCHEDULE:
Notification of Credit: Commencing in 2004 the Company will determine the Fixed
Monthly Participation Credit and the kWh Credit and shall provide notification of the LCSC to
Schedule 10 customers by January 15 of each calendar year. In 2003, notification of the LCSC
shall occur no later than ten days following issuance of the final order.
Customer Intent to Participate: Customers desiring to participate in this load control
program for the upcoming Irrigation Season shall submit Intent to Participate notification to the
Company by February 15 of each calendar year commencing in 2004. In 2003 , customers shall
submit Intent to Participate notification to the Company within 31 days of the Commission
final order. Customers failing to execute a Load Control Service Agreement after submitting an
Intent to Participate notification shall be ineligible to participate in the program the following
year.
Notification of Load Control Schedule: The Company will provide the participating
Customers the scheduled hours for load control during the Irrigation Season by March 1 of each
calendar year commencing in 2004. In 2003, the Company will provide participating Customers
the scheduled hours for load control during the Irrigation Season within 46 days of the
Commissions final order. Subject to the limitations described in the Load Control Conditions
below, the Company shall have the right to establish at its sole discretion the scheduled load
control hours for each participating customer, based on what the Company deems most
beneficial to its operations. The scheduled load control hours shall be fixed through the
Irrigation Season each year in the Load Control Service Agreement.
Load Control Service Agreement: Commencing in 2004, customers desiring to
participate in this load control program shall execute a Load Control Service Agreement with the
Company by March 31 of each calendar year. In 2003 , customers shall execute a Load Control
Service Agreement with the Company within 67 days of the Commission sfinal order.
Attachment B
Case No. PAC-03-
Staff Comments
03/06/03
FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF TO P ACIFICORP
AND P ACIFICORP'S RESPONSES TO PRODUCTION REQUEST
CASE NO. P AC-O3-
Request No.1: Please provide the proposed amount (rate or rates) for the Load Control
Service Credit (LCSC) in 2003.
Response to Request No.
Month Monthly KWh Credit ($ per
Participation KWh)
Credit ($ per KW -
month)
June $1.20 $0.
July $1.85 $0.
August $2.$0.
September $0.$0.
This response was prepared by Bruce Griswold, Director, Energy Contracts.
Request No.2: Please provide a description of the methodology used to calculate the
LCSC rate, all the supporting calculations, assumptions and related analysis used in the
development of this value.
Response to Request No.
Methodology
From June 1 st, 2003 to September 15th, 2003 , PacifiCorp has the right to physically curtail
the irrigation pumping load associated with Idaho Schedule 10 customers for two six-continuous-
hour blocks per week (Monday-Saturday). PacifiCorp must nominate in advance (March 31
2003) those days of the week it will curtail irrigation pump load. Physical curtailment applies to
hours ending 1400 through 1900 Pacific Prevailing Time (2PM to 8PM Mountain Prevailing
Time). In exchange for physical curtailment rights, PacifiCorp foregoes the retail revenue
associated with Schedule 10 customers' 1 load and also pays a monthly credit to the enrolled
Schedule 10 customers. This credit will be based on the customer s three-year average historical
load level.
Pricing is based on PacifiCorp s next best alternative to serve East Side Load, the
forward firm energy market at Mona. PacifiCorp will take six of the most expensive hours in a
given day (HE 14-19 PPT), twice a week. The average hourly prices for these days are
determined by applying the current monthly forward heavy load hour price at Mona (June, July,
August, and September of2003) to the HE 1400-1900 scalars found in the ID Load Control
I The weighted average retail rate of $43.58/MWh is used as the opportunity cost to PacifiCorp of curtailing
Schedule 10 customers. This weighted average is based on the schedule 10 three retail rates ($54.32/MWh
$38.02/MWh, and $25/MWh), along with the MWh associated with these rates from April 1, 2000 to March 312001. Attachment C
Case No. PAC-03-
Staff Comments
03/06/03 Page 1 of
analysis. The net value PacifiCorp receives from the curtailment product, on a $/MWh basis, is
the difference between the average scaled hourly Mona price (by month), and the Schedule 10
weighted average retail rate.
PacifiCorp has estimated that roughly 20% of the irrigation load committed to the
program will be unavailable for curtailment when actually called upon. To account for a portion
of the projected irrigation load being unavailable during the curtailment periods, PacifiCorp
adjusted the monthly credit down by approximately 20%. The reasons that load may be
unavailable for curtailment include equipment failure, unexpected differences between the
estimated 3-year load versus actual load, outright failure of customer to curtail, and customer
tennination from the program for previously failing to curtail.
Additional information is also provided as Attachment ID-P AC-03-3 1.
This response was prepared by Mark Klein, Director, Pricing and Structuring.
Attachment C
Case No. PAC-03-
Staff Comments
03/06/03 Page 2 of
CERTIFICATE OF SERVICE
HEREBY CERTIFY THAT I HAVE THIS 6TH DAY OF MARCH 2003
SERVED THE FOREGOING COMMENTS OF THE COMMISSION STAFF, IN
CASE NO. PAC-03-, BY MAILING A COpy THEREOF, POSTAGE PREPAID, TO
THE FOLLOWING:
DOUG LARSON
VICE PRESIDENT REGULATION
ACIFICORP
1407 W NORTH TEMPLE
SALT LAKE CITY UT 84116
DATA REQUEST RESPONSE CENTER
P ACIFICORP
825 NE MUL TNOMAH, SUITE 800
PORTLAND, OR 97232
sJgT
CERTIFICATE OF SERVICE