20030314Comments.pdf

SCOTT WOODBURY
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
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UTILiTiES COr'H'HSSrON
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
PACIFICORP DBA UTAH POWER & LIGHT
COMPANY FOR APPROVAL OF AMENDED
ELECTRIC SERVICE SCHEDULE 72
IRRIGATION LOAD CONTROL CREDIT RIDER PROGRAM.
CASE NO. P AC-O3-
COMMENTS OF THE
COMMISSION STAFF
TO P ACIFICORP
ALTERN A TIVE SCHEDULE 72
METHODOLOGY
COMES NOW the Staff of the Idaho Public Utilities Commission, by and through its
Attorney of record, Scott Woodbury, Deputy Attorney General, and submits the following
comments in response to PacifiCorp s Alternative Schedule 72 methodology.
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. On March 6 , 2003 the Commission Staff (Staff) and the Idaho
Irrigation Pumpers Association (Irrigators) submitted comments. On March 10, 2003 the
Company submitted Reply Comments. At its Decision Meeting on March 10, 2003 the
ST AFF COMMENTS TO P ACIFICORP
ALTERNATIVE SCHEDULE 72
METHODOLOGY MARCH 13, 2003
Commission held the agenda item until March 14, 2003 and suggested that the parties work to
find an acceptable method for determining the credit that excluded lost revenue considerations.
After discussion among the parties, the Company filed Supplemental Reply Comments on
March 13 , 2003 identifying an alternate method of calculating the credit that does not include
Lost Revenue.
COMPANY ALTERNATE PROPOSAL
In its filing the Company proposes an alternate method of determining the load reduction
credit. The method assumes the same interruption criteria as originally proposed by the
Company, but assumes that interrupted energy would be shifted from Super Peak Hours to Light
Load Hours instead of not used. Therefore, the value of interruption becomes the difference in
energy price between Super Peak Hours and Light Load Hours. Due to program uncertainties
the Company proposes to pass 70% of that difference back to participating irrigators. The
Company identifies the uncertainties as a) the amount of load that actually is shifted, b) the hours
of the day that load is actually shifted to, c) the level of load 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.
The rates associated with the credit have been recalculated by the Company and are
contained in the Company s filing. As in its previous proposal, the credit is applied first to offset
the customer s monthly demand charge. The new credit rates are higher than those previously
proposed by the Company. The larger credit should encourage greater irrigator participation.
Finally, the Company proposes a review of the program at the end ofthe 2003 irrigation
season.
STAFF COMMENTS
For the 2003 irrigation season the Staff supports the alternate method proposed by the
Company in its Supplemental Reply Comments. The proposal avoids the Lost Revenue issue by
assuming that energy consumption and Company revenues will not change. Energy use is
presumed to shift to a lower cost period. This cost difference is the value captured in the credit
70% of which would be returned to program participants. The Company s proposal also
STAFF COMMENTS TO P ACIFICORP
ALTERNATIVE SCHEDULE 72
METHODOLOGY MARCH 13 2003
provides a substantial credit to participating irrigators and should allow a program to be
implemented in 2003.
As a point of reference, Staff notes that the rate difference between Schedule A and C
that existed in the previous tariff was about $1.41/kW-month. This rate was for very similar
service, which allowed for interruptions of up to 12 hours per week.
Staff rejects the Company s proposal that program uncertainties should include "the
amount of load that actually is shifted", because, if the interrupted energy is not shifted it is lost
which brings Lost Revenue considerations back into the determination of the credit. Staff
believes that the change in the uncertainty factor from 80% to 70 % is justified by the fact that all
of the interrupted load may not be shifted to Light Load Hours, but may be shifted to Heavy
Load Hours that are not Super Peak Hours. If this happens, it decreases the value of the load
shift and, therefore, the credit.
Staff supports the Company s proposal to file a report at the end of the season. The 30%
uncertainty" reduction in the value of the credit proposed by the Company is one of the items
that should be addressed in the report. A year s experience should be beneficial in determining
the appropriate credit discount. As previously proposed, Staff recommends a filing date no later
than December 1 , 2003. The filing of the Company s report should initiate a process of program
review that should result in a program for 2004 and possibly beyond. Staff continues to support
and recommend the non-rate issues addressed in its initial comments.
In summary, Staff believes that the Company s proposal is a reasonable compromise and
should be approved in order to get the program in place for this irrigation season. Questions
related to the methodology, including the question of whether or not 70% is the proper discount
can be addressed in greater detail in the evaluation report that should be required to be filed this
fall.
Respectively submitted this 1'\
13
day of March 2003.
~d.fi?Y7;P~
Scott Woodbury
Deputy Attorney General
Technical Staff: Keith Hessing
Dave Schunke
s W:i :umisc/ comments/paceD3.3 swdes khrep 1ycom
STAFF COMMENTS TO PACIFICORP
ALTERNATIVE SCHEDULE 72
METHODOLOGY MARCH 13, 2003
CERTIFICA TE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 13TH DAY OF MARCH 2003
SERVED THE FOREGOING STAFF COMMENTS TO PACIFICORP ALTERNATIVE
SCHEDULE 72 METHODOLOGY, IN CASE NO. P AC-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
E- MAILED TO doug.larson(fYpacificorp. com
DATA REQUEST RESPONSE CENTER
P ACIFICORP
825 NE MUL TNOMAH, SUITE 800
PORTLAND, OR 97232
MAILED TO datarequest(fYpacificorp.com
MAILED TO BOB LIVELY AT
bob .livel y(fYpacificorp. com
SECRETARY
CERTIFICATE OF SERVICE