20031230ID Irrigation Pumpers Assoc.pdf

Eric L. Olsen ISB# 4811
RACINE, OLSON, NYE, BUDGE &
BAILEY, CHARTERED
O. Box 1391; 201 E. Center
Pocatello, Idaho 83204-1391
Telephone: [phone]
Fax: [phone]
RECEIVED 0FILED
lOD3 DEC 3et PM 4: 29
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UTiliTIES Cm'jrHSSION
Attorneys for the Idaho Irrigation Pumpers Association, Inc.
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION
OF PACIFICORP DBA UTAH POWER &
LIGHT COMPANY FOR APPROVAL OF
PROPOSED CHANGES TO ELECTRIC
SERVICE SCHEDULE 72-IRRIGATION
LOAD CONTROL CREDIT RIDER
PROGRAM.
Case No. PAC-O3-
IDAHO IRRIGATION PUMPERS
ASSOCIATION, INc.'
COMMENTS TO PROPOSED
CHANGES AND EVALUATION
REPORT
COMES NOW the Idaho Irrigation Pumpers Association, Inc. ("Irrigators ), through
undersigned counsel, and hereby respectfully submits its comments on PacifiCorp s proposed
changes to the optional Irrigation Load Control Credit Rider Program ("Program ) and the
corresponding Evaluation Report ("Report"
The Inigators want to reaffirm their support for the overall Program.The
monitoring and evaluation clearly shows that it is a viable demand side resource that can be
utilized to mutually benefit PacifiCorp, the Irrigators, and PacifiCorp s other customer classes.
Given the uncertainty of maintaining the current level of BP A Exchange Credit benefits, the
Program will become even more critical in the future to ensure affordable rates for the Inigators
while at the same time benefitting PacifiCorp s other customer classes. The Irrigators believe
that PacifiCorp has worked hard to implement and refine the mechanics of the Program to the
benefit of all parties involved. The Irrigators are also appreciative of PacifiCorp s efforts to
IRRIGATORS' COMMENTS - 1
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meet and discuss the Program directly with the Irrigators.
PacifiCorp s filing proposes six new changes to the existing Program. The
Irrigators believe that all the requested changes will be beneficial to timely implementation and
continued operation of the Program and recommends that the Commission approve and
implement the same as soon as practical without a formal hearing. One concern the Irrigators
had with the Program s initial filing in PAC-03-03 was that the Irrigators did not have the
opportunity to review and comment on the Load Control Service Agreement ("Service
Agreement"). The current filing requires that PacifiCorp would provide its inigation customers
with the Service Agreement by January 15 , 2004, and the Irrigators have not yet been provided
with a copy of the Service Agreement. The Irrigators respectfully request that the Commission
require that the Service Agreement be provided to the Irrigators and Commission Staff for
review and comment prior to dissemination. The Irrigators commit to promptly review the
Service Agreement and get its comments to PacifiCorp to avoid delay.
Generally, the Report indicates that the Program as a whole is a cost effective
means of reducing a portion of PacifiCorp s the peak electricity demand, thereby allowing
PacifiCorp to avoid meeting a portion of its peak demand through market power purchases.
However, the Report does not fully flush out the all the Program s benefits. Specifically, the
Report indicates that in addition to being a demand-side resource, it also results in energy
savings/conservation. Report at II-3. However, these benefits were not quantified and the
Irrigators respectfully request that the Commission require that PacifiCorp continue to monitor
and quantify this potential Program benefit and give it appropriate weight in the monthly credit
pricing methodology.As an apparent corollary, the Report summarily concluded that the
Program participants were not shifting their load from the peak periods they were curtailed to the
IRRIGATORS' COMMENTS - 2
off-peak periods. Report at II-2. The Irrigators respectfully request that the Commission require
that PacifiCorp continue to provide data to support this conclusion or require it to monitor and
quantify this claim going forward inasmuch as is was one of the primary uncertainty elements
that went into the reducing the price for the Program credit.See Order No. 29209, at 5.
Notwithstanding the above conclusions, the Report also summarily concludes that the Program
does not affect a participant's monthly peak demand (or load factor) because it does not reduce
demand on non-control days. Report at II-5. As a consequence, no benefit was attributed to a
participant's likely reduced demand factor.But the Irrigators believe that the opposite
conclusion should have been reached and that this benefit should be given proper weight in the
monthly credit pricing methodology.As such, the Irrigators respectfully request that the
Commission require that PacifiCorp continue to monitor and quantify the reduction in demand
due a farmer s participation in the Program. Finally, the Report indicates the load control
equipment was extremely reliable and that the Program participants curtailed their irrigation
activities during the required times. Report a t I I-I. This high degree 0 f reliability calls into
question the continued use of the 30% uncertainty factor to reduce the amount of monthly credit.
PacifiCorp intends to file in early January its calculation of the proposed monthly
credits to be paid to Program participants in 2004. By supporting PacifiCorp s proposed changes
to the Program, the Irrigators are in no way endorsing the cunent credit pricing methodology.
The Irrigators fundamentally disagree with PacifiCorp s methodology because it focuses solely
on proj ected market prices to the exclusion of the avoided cost of PacifiCorp ' s other supply side
resource options, as well as the other potential Program benefits and certainties addressed in the
Report. The Inigators respectfully request that the Commission require PacifiCorp to provide
the Irrigators with the credit calculation and allow comments to be filed on the calculation of the
IRRIGATORS' COMMENTS - 3
same. The comment process on the credit calculation for the 2004 irrigation season should not
hold up the implementation of the Program for this coming year.
The I nigators believe that the Program should continue to be monitored 0 n an
annual basis to refine and improve it, to quantify the benefits derived thereby, to evaluate and
revise the pricing mechanism in light of all benefits, and to address the questions the Irrigators
have raised about the Report. Further, the continued review of the Program would also be
beneficial to the Commission in evaluating the various supply-side actions PacifiCorp will be
taking in the future in light of its cunent Integrated Resource Plan.
Respectfully submitted this 30th day of December, 2003.
RACINE, OLSON, NYE, BUDGE &
BAILEY, CHARTERED
ERr L. SEN
Attorneys for e Idaho Irrigation Pumpers
Association, Inc.
IRRIGATORS' COMMENTS - 4
CERTIFICATE OF SERVICE/MAILING
I HEREBY CERTIFY that on this 30th day of December, 2003 , I served a true, conect
and complete copy of the Idaho Irrigation Pumpers Association, Inc.s Comments to Proposed
Changes and Evaluation Report to each of the following, via u.S. Mail, e-mail or hand delivery:
Jean D. Jewell, Secretary
Idaho Public Utilities Commission
O. Box 83720
472 W. Washington Street
Boise, Idaho 83720
E-mail: jjewell~puc.state.id.
Hand Delivery/E-mail
Bob Lively
Manager Regulation
PacifiCorp
825 NE Multnomah, Suite 800
Portland, OR 97232
u.S. Mail
. OLSEN
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