20110321Comments.pdf

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NEIL PRICE
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
BARNO. 6864
ZOil 21 PM 2= 36
Street Address for Express Mail:
472 W. WASHINGTON
BOISE, IDAHO 83702-5918
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION OF )
PACIFICORP, DBA ROCKY MOUNTAIN )
POWER, REQUESTING FOR APPROVAL OF )
REVISIONS TO ITS DISPATCHABLE )
IRRIGATION LOAD CONTROL PROGRAM. )
)
CASE NO. PAC-E-ll-06
COMMENTS OF THE
COMMISSION STAFF
COMES NOW the Staff of the Idaho Public Utilties Commission, by and through its
attorney of record, Neil Price, Deputy Attorney General, and in response to the Notice of Application
and Notice of Modified Procedure issued in Order No. 32173 on February 4,2011, submits the
following comments.
BACKGROUND
On January 20,2011, PacifiCorp dba Rocky Mountain Power ("Rocky Mountain" or "the
Company") fied an Application, pursuant to Idaho Code §§ 61-502 through -503 and Commission
Rule of Procedure 52, IDAP A 31.01.01.052, requesting an Order from the Commission allowing the
Company to enact prospective changes to its Dispatchable Irrigation Load Control Program
("Program").
The Schedule 72A program is a voluntary program available to irrigation customers receiving
service under Schedule 10. Program participants agree to curtail demand during the Company's
summer peak usage period by tuing off their pumps intermittently, total curtailment not to exceed
STAFF COMMENTS 1 MARCH 21, 2011
52 hours for any Program paricipant, during the summer season (June 1 to August 31). The Company
is authorized to tum off pumps, with a prior day notification, from 11 a.m. to 7 p.m. MDT, Monday
through Friday, during the Program season.
Rocky Mountain noted that Program paricipation has now reached 278 MW of curtailment in
2010.
According to the Company, the success of the Program has led to certain voltage control
problems. In 2010, the Company claims that it was able to mitigate the problem somewhat by
implementing a "phasing process to ramp load off and back on during dispatch events." Rocky
Mountain states that it is now necessar to shift some Program participants to other load control hours
in order to lessen the magnitude of load loss during summer peak load hours.
Rocky Mountain proposes the following modifications to the Schedule 72A program:
1. The addition of language, similar to that found in Idaho Power Company's Schedule 23
Irrigation Peak Rewards Program, allowing the Company to reject prospective Program
paricipants based on, among other criteria, the Program's cost-effectiveness and the
impact of Program participation on the Company's transmission and distribution system;
2. Elimination of the graduated rate schedule;
3. Fixing the Load Control Service Credit ("LCSC") at $25.30 per kW per year;
4. Changing the opt-out penalty schedule from the current market price of
energy to a graduated scale (more fully described in the Application);
5. Other administrative language changes in the Tariff including: modifying
language about continued Program participation; elimination of the
internet-access requirement; eliminating redundant language regarding the
calculation of the credit and references to air-time communication costs;
discontinue the use of equipment charges; and substituting the phrase
"Program Season" for "irrigation season" in the tariff.
STAFF ANALYSIS
The Dispatchable Irrigation Load Control Program began as a pilot in 2007, and was limited to
45 MW. Through settlement negotiations in the 2007 general rate case (PAC-E-07-05), the pilot status
of the Program was lifted, and the Program was open to all eligible participants. The Stipulation set
forth the terms and conditions of the Program for the 2008 and 2009 season, which saw tremendous
growth in paricipation levels reaching over 250 MW. In the Decision Meeting on November 23,
2009, the Commission approved Rocky Mountain Power Tariff Advice 09-05, Update Schedule 72A.
The fiing represented an agreement between the Company and the Idaho Irrigation Pumpers
STAFF COMMENTS 2 MARCH 21, 2011
Association ("IIPA") on the terms and conditions of the Program for 2010 through 2012. The
agreement specifically addressed the level of the LCSC, length of the Program season, revision of the
available dispatch hours, and continual provision of Program results in the Company's anual DSM
report fied with the Commission. Though a jointly signed letter of support, each party agreed "to
these terms and conditions..., with all other terms and conditions remaining unchanged as specified" in
the accompanying tariff sheets. Staff has included the Company's Tariff Advice and the letter as
Attachment A to its comments. While the Commission approved the tariff advice, the agreement itself
was not submitted by Rocky Mountain for Commission approval. Perhaps the overarching decision
before the Commission in this case is whether the agreement between the Company and its
participating irrigators is binding, thus cementing the terms and conditions through the 2012 Program
season.
Staff believes that the agreement was negotiated in good faith, with the understanding by both
the Company and IIP A that the terms and conditions would remain in place through the 2012 Program
season. The Commission has received numerous public comments echoing this sentiment. While
Staff does not believe Rocky Mountain instructed paricipants to do so, many have said that they
invested in upgrading equipment and altered management of their operations under the premise that the
Program would be available in its curent status for a minimum of three years at the time of
negotiation. Staff considers the agreement binding, and if the Commission agrees, then Staff
recommends rejection of the Company's filing in its entirety. Should the Commission be inclined to
address the merits of the proposed revisions, Staff respectfully submits the following comments.
Staff has reviewed the Company's Application and believes that while a number of the
modifications are supportable, two revisions are unjustified and should be denied by the Commission.
Staff does not support the Company's request to reduce the Credit from $30 per kW-yr to $23.50 per
kW-yr, nor the proposed language modifications providing Rocky Mountain discretion to limit
participation for reasons cited as "necessary to ensure the effective operation of the Program and utility
system." See PAC-E-11-06 Application, page 3.
The Company's stated basis for violating the agreement and requesting revisions to the
Program are to "make certain adjustments... to reduce the costs of the (P)rogram and increase its
effectiveness" (P AC- E-1 0-07, Hunter Rebuttal, page 8), and to mitigate voltage excursion issues on its
transmission and distribution system due to the size of the Program and the corresponding magnitude
of the load loss during dispatch events. See Application, page 2. Staff recognizes that, while
providing significant benefits to the Company and all its customers, there are technical issues
STAFF COMMENTS 3 MARCH 21, 2011
associated with a program of this magnitude. That said, Staff believes Rocky Mountain has already
taken great steps in working around the technical problems, and the current proposal lacks sufficient
evidence that it would provide a resolution to what the Company perceives as an issue.
The Company has been experiencing voltage excursions on its distribution system allegedly
due to the Program prior to the 2010 season. To mediate voltage excursions, Rocky Mountain began
"phasing in" or stair-stepping curtailment over three separate four-hour dispatch blocks in 2010. i The
agreement signed in 2009 extended the available dispatch hours from 2:00 pm until 8:00 pm to
11 :00 am until 7:00 pm, facilitating the phasing in approach to load curtailment. This has required the
Company to take more of an "intellgent scheduling" approach to load curtailment, and obviously
reduced the maximum amount of curailed load at any given point. According to Rocky Mountain's
2010 Idaho Irrigation Load Control Program Final Report ("2010 Report"), peak load curtilment
occurred in the 3:00 pm to 6:00 pm timeframe, and averaged nearly 130 MW, or just under half the
load under contract. The Company states that while this approach "was effective in stabilizing the
voltage excursions, doing so diluted the total control available durng any peak hour when the
Program's resources are needed to manage system demands." See Hunter page 3, lines 8-10.
Staff agrees that the phasing in curtailment reduces the amount of load reduction at any given
moment, but believes the Company devalues the benefit of having such a substantial amount of
curailed load available. The extended timeframe for dispatch hours stil fall within heavy load hours
in what is generally the most expensive season of the year to procure energy. Based on the Company's
net power cost filing in the 2010 general rate case, July and August represent the two highest cost
months for providing electricity. The extended dispatch hours may afford the Company more
flexibilty to run its gas-fired generation plants or make off-system sales. Rocky Mountain notes that
this '''smar implementation' would augment existing infrastructure assets and perhaps improve Grid
performance." See 2010 Report, page 10. The Company acknowledges that curtailment "must
absolutely be executed in an intellgent fashion," and going forward, wil "(d)esign dispatch protocol to
extract additional value from a 'smart-grid' approach." Id. at 28-29. Staff commends the Company's
efforts toward maximizing the numerous benefits of the Program, and believes approving the proposed
language to restrict participation would only hinder its efforts going forward.
) A fourth block, 7:00am-1 I :00 am, was instituted that shifted 20MW off of the Big Grassy substation due to continued
voltage issues.
STAFF COMMENTS 4 MARCH 21, 2011
Staff also believes that reducing the LCSC at this time is inappropriate. The Company has
provided no technical analysis to show this would improve the cost effectiveness of the Program or
resolve the voltage excursion problem the Company purorts to address. While it is clear that reducing
the LCSC by nearly 16 percent would lower the cost of the Program, the Company has not attempted
to quantify the impact that would have on participation. The potential loss in paricipation could easily
offset any savings from reduced credit payments. If the Company's proposal is approved, it would
take less than an 11 percent reduction in paricipating load to adversely affect the benefit cost ratio of
the Program. The Commission has received several public comments from participants sharing this
sentiment, with one paricipant stating "that the proposed incentives are so low that very few farmers
wil participate and the entire program wil be lost, resulting in higher rates for everybody." Since the
Company did not attempt to quantify the loss of participation due to a reduced LCSC nor its effect on
voltage excursions, as well as the risk of harming the Program's cost effectiveness, Staff does not
believe it is reasonable to reduce the LCSC at this time.
Staff first became aware of possible modifications to the Program through the Company's
rebuttal testimony of Ms. Hunter in the 2010 general rate case. In that proceeding, Ms. Hunter first
proposed the participation selection language, change in opt-out penalty, and reduction in the
participation credit? There were no supporting tariffs fied with the Company's request at that time,
and through Order No. 32196, the Commission denied the Company's proposed modifications as part
of the general rate case. Rocky Mountain resubmitted the revised tariffs to the Commission as Tarff
Advice No. 11-01 on January 10, 2011. Staff contacted the Company and expressed its concerns that
the revisions fell outside the normal parameters ora tariff advice, and requested the Company
withdraw and refie as a formal case. The Company complied, resulting in the current case.
Staff believes the timing and the type of modifications proposed by the Company are in
response to the Commission's findings in the 2010 general rate case. Staff believes that Rocky
Mountain's current request is the result of the Commission's decision to consider the Program as a
system resource, and the costs being allocated accordingly across all jurisdictions. It is clear that the
Company has proactively addressed the voltage excursion issue, and as stated before, does not rely on
any cost effectiveness test in proposing a reduced LCSC. Rocky Mountain's filing indicates that the
2 At that time, the Company's proposal was to reduce the participation credit to $25 per kW for the 201 I season, not $25.30
per kW as currently proposed, and returning to $30 per kW for the 2012 season.
STAFF COMMENTS 5 MARCH 21, 2011
requested LCSC is expressly a function of cost allocation.3 See Hunter, page 8, lines 209. If the
ultimate rationale for this filing is cost recovery uncertainty, Staff argues that not only are the
proposals in this case insufficient to address this, but the Company is currently working with the
multi state process (MSP) committee and each jurisdiction on this matter. This fiing does not represent
the proper forum for handling cost recovery issues.
Should the Commission decide that the terms and conditions of Tariff Schedule 72A are subject
to change, Staff does not oppose the Company's modification of the opt-out penalty. Curently, the
penalty is based on the day-ahead market price Rocky Mountain would have to pay to supply the non-
curiled power. Approval in this Application would result in a graduated reduction in the LCSC paid
depending on the number of opt-outs a customer elects to take. Under the proposal, there would be no
penalty for the first opt-out, then a 10 percent reduction in credit pay for two opt-outs, then further
reductions through the sixth opt-out, in which the participant forfeits any credit payment. Staff
believes this approach better aligns participant involvement in the Program with the cost imposed by
opting out. This also provides certainty of the economic impact participants face when making the
operational decision of whether or not to opt out of an event. That said, the opt-out rate has
traditionally been low (~3 percent), and has not materially affected the cost effectiveness of the
Program.
If the Commission decides to leave the LCSC at the current level, Staff finds it unnecessar to
remove the graduated credit schedule. The Company's filing replaces the schedule with its proposed
$25.30 per kW -yr value. While Staff does not envision Program participation levels to fall below
175 MW (the current threshold in which a lower LCSC would occur), keeping the graduated payment
schedule in the tariff assures the LCSC adheres to the agreement made by the paries and approved by
the Commission.
Staff believes that the remainder of the proposed revisions results in a clear and concise tariff.
Of the proposed changes, Staff supports the elimination of language regarding the internet access
requirement, redundant language regarding the calculation of the credit and references to air-time
communication costs, discontinuance of equipment charges, and substituting the phrase "Program
Season" for "irrigation season". These modifications are minor, and more accurately reflect the
operation of the Program.
3 The $25.30 per kW-yr value is the result ofthe Company's solicited LCSC of $25 per kW-year form the 20 i 0 general rate
case allocated to jurisdictions outside ofIdabo (94 percent of the cost) plus Idaho's allocation (6 percent) oftbe current $30
per kW-yr credit, thus ($25 x .94) + ($30 x .06) = $25.30.
STAFF COMMENTS 6 MARCH 21, 2011
ST AFF RECOMMENDATIONS
Staff recommends that the Commission deny the request of the Company to modify Schedule
72A, Dispatchable Irrigation Load Control Credit Rider Program as the terms and conditions were
agreed upon for the 2010 through 2012 seasons on October 26, 2009. Should the Commission
determine that Program changes are allowed, Staff recommends that the Commission approve the
following modifications to the Schedule 72A tariff: changing the phrasing from "irrigation season" to
"Program season", elimination of redundant language regarding the calculation of the Credit,
references to air-time communication costs, language regarding the use of load control equipment, and
the revised Opt-Out penalty schedule. Staff recommends that the Commission deny the Company's
request to reduce the Credit value from $28 per kW-yr to $25.30 per kW-yr. Staff also recommends
denial of language modifications that grant the Company discretion in paricipation based on the
revised criteria proposed by the Company. In doing so, Staff finds that paricipation in subsequent
Program seasons is well-defined in the current tariff language. To the extent that the Commission
accepts this recommendation, Staff believes it is appropriate to maintain the current language in the
tariff requiring a 30 Hp minimum pump size.
Respectfully submitted this i9.~ day of March 2011.
~)Ç'
Deputy Attorney General
Technical Staff: Bryan Lanspery
i:umisc:commentslpacel 1.6npbl comments
STAFF COMMENTS 7 MARCH 21,2011
~~~~OUNTAIN
201 South Main, Suite 2300
Salt Lake City. Utah 84111
October 28, 2009
VI ELECTRONIC FILING
Jean D. Jewell
Commission Secreta
Idaho Pt;b1ic Utilties Commission
472 W. Washigton
Boise, ID 83702
Attention:Jean D. Jewell
Commission Secretar
RE: Tariff Advice 09-05, Update Schedule 72A to reflect terms of an agreement between
Rocky Mountain Power and the Idaho Irrigation Pumper's Association for the
Dispatchable Irrgation Program through the end of the 2012 Irrgation Season.
Rocky Mountan Power, a division of PacifiCorp, (the "Company") hereby fies Tariff Advice
09-05 for electronic fiing contaning the proposed revisions to the Company's taff Schedule
72A - Dispatchable Irrgation Load Control Credit Rider Program. Rocky Mountan Power
hereby submits a clean and legislative copy of each sheet contanig proposed revisions along
with a letter agreement between the Company and the Idaho Irrgation Pumpers Association.
Rocky Mountain Power respectfuly requests ths application be processed under the
Commission's Modified Procedur with an effective date of December 31, 2009.
The purose of this fiing is to update taff Schedule 72A to incorporate minor modifications to
the program agreed to between the Company and the Idaho Irrgation Pumper's Association
("LIP A"). The curent taiff agreement for the load control service credit ended afer the 2009
irrgation season. Company and lIP A representatives met on October 6, 2009 to negotiate a new
agreement. The paries successfully negotiated a three-year agreement for 2010 through 2012.
Attached is a copy of the signed agreement executed by representatives of the two paries.
Rocky Mountain Power submits the following proposed revisions to the Dispatchable Load
Control Credit Rider Program sheets:
Four Revision of Electrc Service Schedule Sheet No. 72A.1
Four Revision of Electric Service Schedule Sheet No. 72A.2
Fourth Revision of Electrc Service Schedule Sheet No. 72A.3
Sheet No. 72A.l - Revise the season for the dispatch progr from the curent period of June 1
to September 15 to the proposed period of June 1 to August 31.
Sheet No. 72A.2 - Extend the curnt paricipation schedule for the 2008 and 2009 seasons
though the end of the 2012 irrigation season.
At tachment A
Case No. PAC-E-11-06
B. Lanspery i Staf f
3/21/11 Page 1 of 12
Idaho Public Utilties Commission
October 28, 2009
Page 2
Sheet No. 72A.3 - Revise the available dispatch hours from the curent period of 2:00 PM to
8:00 PM to the proposed period of 11 :00 AM to 7:00 PM. The additiona hour wil help faciltate
phasing in and out of dispatch events. Shifting the ending time forward one hour wil provide
additional time to the pumpers to check that their irrgation systm is operating correctly before
it gets dak. Remove the 2007 reference from the load control section of the taff.
If you have any questions please contact Ted Weston at (80l) 220-2963 or email
ted. westonCipacificorp.com.
Very try your,
~K~M,í
Jeffrey K. Larsen
Vice President, Regulation
Enclosures
At tachment A
Case No. PAC-E-11-06
B. Lanspery i Staff
3/21/11 Page 2 of 12
Agreement between Rocky Mountain Power
and Idaho Irrigation Pumpers Association
At tachment A
Case No. PAC-E-11-06
B. Lanspery, Staff
3/21/11 Page 3 of 12
~~'lMOUNTAIN
Jeffrey K. Larsen
Vice President, Regulation
One Utah Center
20/ S. Main Street, Suite 2300
Salt Lake City, UT 84///
8'JI.220.4907
October 21, 2009
Idaho Irrigation Pumpers Association, Inc.
201 East Center
PO Box 1391
Pocatello, ID 83204
Attn: Mark Mickelsen
Eric Olsen
Re: Idaho Tariff Schedule 72A Dispatchable Load Control Service Credit Rider Program
Settlement Terms
Dear Mark and Eric:
The purose of this letter agreement is to memorialize the October 6, 2009 discussions between
representatives of Rocky Mountain Power ("Company") and the Idaho Irigation Pumpers
Association, ("IIPA"). The Company and IIP A collectively are referred to herein as the
"Parties". At that meeting, the Paries discussed the results of the dispatchable irrigation
program to-date and negotiated the post-2009 terms of such program.
:l
For the 2008 and 2009 irrigation seasons the dispatchable irrigation program was governed by
the stipulation to Rocky Mountain Power's Case No. PAC-E-07-05, approved in Order No.
30482 by the Idaho Public Utilities Commission. Tariff Schedule 72A was modified to reflect
the terms of the stipulation. Since Tariff Schedule 72A does not address the terms for irrigation
seasons after 2009, the Paries have agreed to the following changes in the terms and conditions
of the dispatchable irrigation program under Tarff Schedule 72A to address the post-2009
treatment of the program:
1. extend the current participation schedule for the irrgation seasons through the end of the
2012 irrigation season;
2. extend the current $2.00Ikw-yr incentive for participation at 175 MW or greater. If
participation levels are at 175 MW or greater then all participants would be paid $28.00
plus a $2.00 incentive totaling $30.00. If the program participation levels are less than
175 MW then all participants would be paid according to the Participation Credit
Schedule listed on Electric Service Schedule 72A, Sheet No. 72A.2;
3. revise the dispatch program season from the current period of June 1 to September 15 to a
new period of June 1 to August 31 of each year;
Attachment A
Case No. PAC-E-II-06B. Lanspery, Staff
3/21/11 Page 4 of 12
4. revise the available dispatch hours from the current period of 2:00 PM to 8:00 PM to a
new period of 11 :00 AM to 7:00 PM. The change in times will heLp facilitate phasing in
and out of dispatch events as well as provide additional time to the pumpers to check that
their irrgation system is operating correctly before it gets dark; and,
5. continue to provide results of the Dispatchable Irrigation program in the DSM report fied
annually with the Idaho Commission.
Furthermore, the Parties agree to these terms and conditions as reflected as revisions to the
current Tariff Schedule 72A, with all other terms and conditions remaining unchanged as
specified in the attached tariff sheets. The Paries will support these changes to Tariff Schedule
72A in a Tariff Advice fiing made by the Company for Commission approval and represent that
they are in the public interest.
J ey K. Larsen
Vice President Regulation
The Paries have negotiated the changes to tariff Schedule 72A in good faith and by their
signatures below acknowledge and agree to the terms as detailed above.
By:
Jeffr
Vi
2 t ain Street, Suite 2300
Salt Lake City, DT 84111
Date:j()P-( Æ97 7 ;
Date: ItJ/Zó /&9By'En sen
Attorney for IIP A
201 East Center PO Box 1391
Pocatello, ID 83204
Attachment A
Case No. PAC-E-11-06
B. Lanspery, Staff
3/21/11 Page 5 of 12
Revised Tariffs
At tachment A
Case No. PAC-E-11-06
B. Lanspery, Staf f
3/21/11 Page 6 of 12
~~~,"~OUNTAIN
I.P.U.C. No.1
Fourth Revision of Sheet No. 72A.l
Canceling Third Reviion of Sheet No. 72A.l
ROCKY MOUNAIN POWER
ELECTRIC SERVICE SCHEDULE NO. 72A
STATE OF IDAHO
Dispatchable Irrigation Load Control Credit Rider Program
PUROSE: This optional taiff allows Customers to participate in a dispatchable control service
interrption program in exchange for a Load Control Service Credit (LCSC). Customers participating in this
program wil be considered participants in the Irigation Load Control Credit Rider program.
PARTICIP A nON: Prior to paricipation, and in order to qualifY under this Schedule, Customers
must execute a Load Control Service Agreement (LCSA) with the Company. Paricipants in the
dispatchable program wil be considered program participants for subsequent years unless the Customer
explicitly communicates the desire to no longer paricipate in the Load Control Credit Rider program.
APPLICABLE: To qualifYing Customers served on Schedule 10 and who have continuous access
to the Internet from May 1 through September 15. Access to the internet beginning May i is required to
allow for program infonnation sharing, training, and communication testing in advance of the control
season. In addition, Schedule 10 Customers paricipating in the dispatchable program must:
(a) Meet minimum irrgation equipment motor load size of30 Hp. The Company may evaluate
individual pumps or motors smaller than 30 Hp to determine if participation is cost-effective or
necessar because such pumps are par of a larger paricipating system.
(b) Use advanced 2-way remote control equipment as specified by the Company to manage ALL
pumping requirements throughout the Company defined Irrigation Season (June 1 through
September 15).
(c) Participate in Company-defined trining to set up their pump sites for dispatch.
(d) Incur air time communication charges for communication transactions exceeding 70 per month.
Charges for communication trsactions in excess of 70 per month wil be deducted from the
Customer's LCSC.
DISPATCHALE PROGRAM SEASON: This rider is applicable from June i to August 31,
annually.
(Continued)
Submitted Under Advice No. 09-05
ISSUED: October 28, 2009 JlFFECTIV: Decembér 31, 2009
Attachment A
Case No. PAC-E-11-06
B. Lanspery i Staf f
3/21/11 Page 7 of 12
~~\~~OUNTAIN
I.P.U.C. No. i
Fourth Reviion of Sheet No. 72A.2
Canceling Third Revision of Sheet No. 72A.2
ELECTRC SERVICE SCHEDULE NO. 72A - Continued
LOAD CONTOL SERVICE AGREEMENT: The Customer and Company wil execute a LCSA
for irrigation load control paricipation. The LCSA shall specify the Load Control kW amount that each of
the Customer's sites shall curtil during each Dispatch Event. The agreement wil also include tyical costs
that the Customer may incur for Early Termination. Once executed, the agreement shall remain in force for
subsequent Irrigation Seasons unless explicitly canceled by the paricipating Customer. Cancellation of an
existing LCSA may occur only between September 16 and May 30 each year.
LOAD CONTROL SERVICE CREDIT: The LeSe for a paicipating site shall be calculated and
issued to the participating customer in the form of a check, or as a credit against the paricipating site
account if an outstading account balance exists that is 30 days or more past due two weeks before the
credit issuance. The LCSC wil be issued no later than October 3 i following each irrigation season. The
LCSC is composed of a Fixed Annual Paricipation Credit that shall remain fixed throughout the Irigation
Season each year. The LeSe shall be computed at the conclusion of the Irrigation Season by multiplying
the Fixed Annual Paricipation Credit times the Load Control kW at the Schedule i 0 metered pump site.
The Load Control kW shall be computed by taking the most recent 2-year demand (kW) average for that
particular site. In situations where the pump has been replaced and/or re-wound the kW shall be computed
by takng the manufacturer's revised nameplate Hp and converting it to the kW using standard engineenng
conversion metrics.
The Fixed Annual Paricipation Credit for 2010,2011 and 2012 is based upon total program paricipation
volumes as defined in the table below (Participation Credit Schedule). The paricipation credit is increased
for each tier of program paricipation volume to encourage participation in the program.
Paricipation Credit Schedule
I Program Partcipation Paricipation Credit
I
Volumes (MW)($IkW-vr)
Less than 1 50 $23.00
150 to less than 1 75 i $26.00 --
175 or greater $28.00
SCHEDULE:
Notification of Credit: The Company wil provide notification of the total LCSC to all eligible
Schedule 10 customers by February 15 each year.
Load Control Servce Agrement: Concurrent with the Notification of Credit referenced above,
the Company wil provide a LCSA listing the amount of the credit the Customer wil receive for the
irrigation season if they elect to participate in the program. Customers who have not previously entered into
a LCSA with the Company and who desire to paricipate in this load control progrm shall sign the LCSA
and return it to the Company by April 15 to indicate their paricipation.
(Continued)
Submitted Under Advice No. 09.05
ISSUED: October 28, 2009 EFFECTIVE: December 31, 2009
At tachmèiiEA- - ..
Case No. PAC-E-11-06
B. Lanspery i Staff
3/21/1:1 Page 8 of 12
~~,l~OUNTAIN
I.P.U.C. No. i
Fourth Revision of Sheet No. 72A.3
Canceling Third Revision of Sheet No. 72A.3
ELECTRC SERVICE SCHDULE NO. 72A - Continued
DISPATCH CONDITIONS: The Company shall have the right to implement a Dispatch Event for
paricipating customers according to the following criteria:
(a) Available Dispatch Hours: I I :00 AM to 7:00 PM Mountain Daylight Savings Time
(b) Maximum Dispatch Hours: 52 hours per Irigation Season
(c) Dispatch Duration: Not more than four hours per Dispatch Event or twelve hours per week
(d) Dispatch Event Frequency: limited to a single (1) Dispatch Event per day
(e) Dispatch Days: Monday though Friday (inclusive)
(f) Dispatch Day Exclusions: July 4 and July 24
DISPATCH COMMICATIONS: The Company wil provide day~ahead notice of intent to
dispatch as well as day-of confirmation communication prior to the dispatch event. Communications wil be
made via voice, text or email messaging depending on each Customer's communication preference.
SPECIA CONDITIONS:
Load Control kW: The Load Control kW amount for the Irrigation Season shall be computed as
follows:
i. The maximum kW for the past two (2) years (or available history) for each of the four irrigation
months shall be avetaged by month (June i through September 15).
2. The average monthly values calculated in Step I above shall be averaged.
3. The output of Step 2 above shall be multiplied by the appropriate participation credit as defined
in the Paricipant Credit Schedule above.
Outages: Uncontrolled outages or other tyes of interrptions do not qualify for payment under the
tariff.
Ownership of Control Equipment: The load control equipment remains the propert of the
Company. Customers may, at their discretion, purchase complementary control components that can work
with the Company's foundational control units. To the extent possible, the Company wil cooperate and
work with local equipment distrbutors in faciltating such additional equipment.
Communication: The Company wil pay the cost of air time communication for up to 70
transactions per month. Additional Customer communication with irigation control equipment is pennitted.
The cost of such transactions wil be the Customer's responsibilty but wil be managed through the
Company (Note: Customer air time communication costs, if any, wil be calculated as a reduction to the
LCSe).
Liquidated Damages: Customers are pennitted to 'opt-out' of five (5) Dispatch Events throughout
the Irrigation Season. Customers electing to 'opt~out of a scheduled dispatch event may do so on the
program's web page, by contacting the program's call center, or by notifying a program field technician.
Each 'opt-out event wil incur a cost resulting in a reduction to the Customer's LCSC. The costs wil be
calculated based on the $/MWh the Company otherwise has to pay for power at the time of the Dispatch
Event. Such $/M prices wil be provided by day ahead on-peak price as published at http://theice.com
and wil be based on the established Four Corners trading hubs.
(Continued)
Submitted Under Advice No. 09-05
ISSUED: October 28, 2009 EFFECTIVE: December 3 I, 2009
Attachment A
Case No. PAC-E-11-06
B. Lanspery i Staff
3 21 11 Page 9 of 12
~~\;~~OUNTAIN
I.P.U.C. No.1
~Fourtb Revision of Sbeet No. 72A.l
Canceling See9Hd IIRevision of Sbeet No. 72A.l
ROCKY MOUNAI POWER
ELECTRC SERVICE SCHEDULE NO. 72A
STATE OF IDAHO
Dispatcbable IrngatioD Load Control Credit Rider Program
PURPOSE: This optional tariff allows Customers to paricipate in a dispatchable control service
interruption program in exchange for a Load Control Service Credit (LCSC). Customers paricipating in this
program wil be considered paricipants in the Irrigation Load Control Credit Rider program.
PARTICIPATION: Prior to participation, and in order to qualify under this Schedule, Customers
must execute a Load Control Service Agreement (LCSA) with the Company. Paricipants in the
dispatchable program wil be considered program paricipants for subsequent years unless the Customer
explicitly communicates the desire to no longer paricipate in the Load Control Credit Rider program.
APPLICABLE: To qualifying Customers served on Schedule 10 and who have continuous access
to the Internet from May 1 through September 15. Access to the internet beginning May 1 is required to
allow for program information sharng, training, and communication testing in advance of the control
season. In addition, Schedule 10 Customers paricipating in the dispatchable program must:
(a) Meet minimum irrigation equipment motor load size of 30 Hp. The Company may evaluate
individual pumps or motors smaller than 30 Hp to determine if participation is cost-effective or
necessar because such pumps are par of a larger paricipating system.
(b) Use advanced 2-way remote control equipment as specified by the Company to manage ALL
pumping requirements thoughout the Company defined Irigation Season (June 1 through
September 15).
(c) Paricipate in Company-defined training to set up their pump sites for dispatch.
(d) Incur air time communication charges for communication transactions exceeding 70 per month.
Charges for communication transactions in excess of 70 per month wil be deducted from the
Customer's LCSC.
IRRIC,....TION DISPATCHABLE PROGRAM SEASON: This rider is applicable- dHFiRg the
JFFigatioR SeasoR from June 1 to August 3 I SeJ'teæàer i 5, annually.
(Continued)
Submitted Under Advice No. 09-0~+
ISSUED: October 28FebFHary i i, 2009 EFFECTIV: DecemberJ..l i, 2009
Attachment A
Case No. PAC-E-11-06
B. Lanspery, Staf f
3 21/11 PagelO of 12
~~~~~OUNTAIN
I I.P.U.C. No. i
::Fourth Revision of Sheet No. 72A.2
Canceling See9Rd Third Revision of Sheet No. 72A.2
ELECTRC SERVICE SCHEDULE NO. 72A - Continued
LOAD CONTROL SERVICE AGREEMENT: The Customer and Company wil execute a LCSA
for irrgation load control paricipation. The LCSA shall specify the Load Control kW amount that each of
the Customer's sites shall curtil during each Dispatch Event. The agreement wil also include tyical costs
that the Customer may incur for Early Termination. Once executed, the agreement shall remain in force for
subsequent Irgation Seasons unless explicitly canceled by the participating Customer. Cancellation of an
existing LCSA may occur only between September 16 and May 30 each year.
LOAD CONTROL SERVICE CREDIT: The LCSC for a participating site shall be calculated and
issued to the paricipating customer in the form of a check, or as a credit against the paricipating site
account if an outstanding account balance exists that is 30 days or more past due two weeks before the
credit issuance. The LCSC wil be issued no later than October 31 following each irrigation season. The
LCSC is composed of a Fixed Annual Paricipation Credit that shall remain fixed throughout the Irigation
Season each year. The LCSC shall be computed at the conclusion of the Irigation Season by multiplying
the Fixed Annual Participation Credit times the Load Control kW at the Schedule 10 metered pump site.
The Load Control kW shall be computed by taing the most recent 2-year demand (kW) average for that
particular site. In situations where the pump has been replaced and/or re-wound the kW shall be computed
by taking the manufactur's revised nameplate Hp and converting it to the kW using stadard engineering
conversion metrics.
The Fixed Annual Paricipation Credit for 2010,201108 and 2012() is based upon total program
participation volumes as defined in the table below (Paricipation Credit Schedule). The paricipation credit
is increased for each tier of program paricipation volume to encourage participation in the program.
Paricipation Credit Schedule
Progr Paricipation Paricipation Credit
__Y2Ll!metiM'!($/kW-yr)
Less than 150 $23.00
150 to less than 1 75 $26.00
1 75 or greater $28.00
SCHEDULE:
Notification of Credit: The Company wil provide notification of the total LCSC to all eligible
Schedule 10 customers by Febru 15 each year.
Load Control Service Agreement: Concurent with the Notification of Credit referenced above,
the Company wil provide a LCSA listing the amount of the credit the Customer wil receive for the
irrigation season if they elect to paricipate in the progrm. Customers who have not previously entered into
a LCSA with the Company and who desire to paricipate in this load control program shall sign the LCSA
and return it to the Company by April 15 to indicate their participation.
(Continued)
Submitted Under Advice No. 09-0~l
ISSUED: Fèbrnary 1 i October 28, 2009 EFFECTNE: J.December 3 i, 2009
At tachTIE;ilE -K
Case No. PAC-E-11-06
B. Lanspery i Staff
3/21/11 Page 11 of 12
~~l~OUNTAIN
I I.P.U.C. No.1
+hFourth Revision of Sheet No. 72A.3
Canceling SeeoDd Third Revision of Sheet No. 72A.3
ELECTRC SERVICE SCHEDULE NO. 72A - Continued
DISPATCH CONDITIONS: The Company shall have the right to implement a Dispatch Event for
paricipating customers according to the following criteria:
(a) Available Dispatch Hours: ll;6:00 APM to 18:00 PM Mountain Daylight Savings Time
(b) Maximum Dispatch Hours: 52 hours per Irrigation Season
(c) Dispatch Duration: Not more than four hours per Dispatch Event or twelve hours per week
(d) Dispatch Event Frequency: limited to a single (1) Dispatch Event per day
(e) Dispatch Days: Monday through Friday (inclusive)
(f) Dispatch Day Exclusions: July 4 and July 24
DISPATCH COMMUCATIONS: The Company wil provide day-ahead notice of intent to
dispatch as well as day-of confirmation communication prior to the dispatch event. Communications wil be
made via voice, text or email messaging depending on each Customer's communication preference.
SPECIAL CONDITIONS:
Load Control kW: The Load Control kW amount for the ~Irrigation Season shall be computed
as follows:
1. The maximum kW for the past two (2) year (or available history) for each of the four irrigation
months shall be averaged by month (June 1 through September 15).
2. The average monthly values calculated in Step 1 above shall be averaged.
3. The output of Step 2 above shall be multiplied by the appropriate paricipation credit as defined
in the Paricipant Credit Schedule above.
Outages: Uncontro1led outages or other tyes of interrptions do not qualify for payment under the
tariff.
Ownership of Control Equipment: The load control equipment remains the propert of the
Company. Customers may, at their discretion, purchase complementary control components that can work
with the Company's foundational control units. To the extent possible, the Company wil cooperate and
work with local equipment distributors in faciltating such additional equipment.
Communication: The Company wil pay the cost of air time communication for up to 70
transactions per month. Additional Customer communication with irrgation control equipment is permitted.
The cost of such trsactions wil be the Customer's responsibilty but wil be managed through the
Company (Note: Customer air time communication costs, if any, wil be calculated as a reduction to the
LeSe).
Liquidated Damages: Customers are permitted to 'opt-out' of five (5) Dispatch Events thoughout
the Irgation Season. Customers electing to 'opt-out' of a scheduled dispatch event may do so on the
program's web page, by contacting the program's call center, or by notifying a program field technician.
Each 'opt-out' event wil incur a cost resulting in a reduction to the Customer's Lese. The costs wil be
calculated based on the $/MWh the Company otherwise has to pay for power at the time of the Dispatch
Event. Such $/MWh prices wil be provided by day ahead on-peak price as published at http://theice.com
and wil be based on the established Four Comers trading hubs.
(Continued)
Submitted Under Advice No. 09-0~+
ISSUED: Febnary II October 28, 2009 EFFECTIV: ~December 3 I, 2009
Attachment A
Case No. PAC-E-11-06
B. Lanspery, Staf f
3/21/11 Page 12 of 12
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 21ST DAY OF MARCH 2011,
SERVED THE FOREGOING COMMENTS OF THE COMMISSION STAFF, IN CASE
NO. PAC-E-11-06, BY MAILING A COPY THEREOF, POSTAGE PREPAID, TO THE
FOLLOWING:
TED WESTON
ID REG AFFAIRS MGR
ROCKY MOUNTAIN POWER
201 S MAIN ST STE 2300
SALT LAKE CITY UT 84111
E-MAIL: ted.weston(ßpacificorp.com
DANIEL E SOLANDER
ROCKY MOUNTAIN POWER
201 S MAIN ST STE 2300
SALT LAKE CITY UT 84111
E-MAIL: danieL.solanderlápacificorp.com
DATA REQUEST RESPONSE CENTER
E-MAIL ONLY:
datarequest(ßpacificorp.com
CERTIFICATE OF SERVICE