20110322ICL Comments.pdf

Benjamin Otto
ISB No. 8292
710 N 6th Street
PO Box 844
Boise, ID 83701
Ph: [phone] x 12
Fax: [phone]
bottoCPidaoconservation.org
RECEI\/E
iOti MAR 2\ PM 4: 58
Attorney for Idao Conservtion League
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MAITER OF THE )
APPLICATION OF PACIFICORP DBA )
ROCKY MOUNTAIN POWER'S )CASE NO. PAC-E-I1-06REQUEST FOR APPROCAL OF )
REVISIONS TO ITS DISPATACHABLE )
IRRGATION LOAD CONTROL )
PROGRAM )
COMES NOW, the Idao Conservation League ("ICL") with the following gelleral cOinents on
Rocky Mountain Power's (RMP) proposed changes.
Curently the irrgation load control program pays paricipants a fixed incentive whtther
they actually curil loads or not. While this is appropriate when tring to t1l~();uage
paricipation, it is not appropriate for long-term operation of the res()urce. Just like apy supply
side resource the irrgation load control program has two values - the value of the abilty to
curil irrgation loads when necessar and the value of actually curling l()ad. As reclltly
approved for Idao Power's Irgation Load Control Program, ICL believes the Commission
should direct all stakeholders to devise a fixed/varable credit scheme.
Changing the incentive strctue from a 100% fixed payment to a fix~varable pRyment
appropriately addresses the dual value of this matue program. The abilty to curil irgation
loads when necessary is a valuable resource for RM and ratepayers. It is appropriate to pay a
ICL's Comments 1 March 21, 2011
certin amount to irrgators for them to essentially stad by. It is also appropriate to pay a
certin amount to irrgators when RM actully curils their loads. What is inappropriate is the
curent incentive that pays irgators the same crdit regardless of the actl utilzation of the
progrm.
Splitting the curent fixed payment to a fixed/variable scheme minimizes costs to
ratepayers while maximizing the value to RMP. It minimizes costs by ensurng ratepayers pay
the full incentive only durng actual curilments. It maximizes value by incentivizing
paricipants to actually curil and thereby receive the payment. Unfortately, RMs
application and the testimony of Ms. Hunter do not provide suffcient detail or analysis to
determine if$25.30 per kilowatt is an appropriate incentive leveL. Assuming it is, ICL supports
the 75%/25% split adopted for Idaho Power.
ICL believes opt-out penalties are importt to ensur the amount of load curailment
RM expects to have available actully responds when needed. ICL support RM proposed
revision because it is clear and simple for the paricipants. This change should allow irrgators to
quickly deterine the cost of the penalty wil outweigh the benefit of opting out. However, if
the Commission decides to enact a fixed/varable credit scheme, then ICL proposes an opt-out
penalty based on a fixed dollar per kilowatt, similar to that recently adopted for Idaho Power.
WHEREFORE, ICL respectfully requests the Commission consider these comments.
DATED this 21 th day of March 2011.
Respectfully submitted,
Benjamin J. Otto
Idao Conservation League
ICL's Comments 2 March 21, 2011
CERTIFICATE OF SERVICE
I hereby certif that on this 21st day of March, 2011 true and correct copies of the
foregoing COMMENTS OF IDAHO CONSERVATION LEAGUE were delivered to the
followig persons via the method of servce noted:
Hand delivery:
Jean Jewell
Commission Secretar (Original and seven copies provided)
Idao Public Utilties Commission
427 W. Washington St.
Boise, ID 83702-5983
Electronic Mail:
Mark C. Moench
Daniel E. Solander
Yvonne R Hogle
PacifiCorp/dba Rocky Mountain Power
201 S. Main St., Suite 2300
Salt Lae City, UT 84111
Daniel.SolanderCPpacificorp.com
Mark.moenchCPpacificorp.com
Yvonne.hogleCPpacificorp.com
!Ú t?~
Benjamin J. Otto
Idao Conservtion League