20151223Comments.pdf

DAPHNE HUANG
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 8370
Street Address for Express Mail:
472W. WASHINGTON
BOISE, IDAHO 83702-5918
Attorney for the Commission Staff
-1I-,\f-.1 :t '.;ii:i_,:t;'=j::l
?$!$ DIC 23 Ptl t?: L?
'l\rt! . f' '"
I ["'i\ii r,-' 1 ".' L.i *','t
UT I LIT ; E*t C Clr,{ t,,t I iiS I OF{
BEFORE THB IDAHO PUBLTC UTILITIES COMMISSION
IN THE MATTER OF PACIFICORP DBA )
ROCKY MOUNTAIN POWER COMPANY'S )
APPLICATION FOR AUTHORITY TO CANCEL )
ELECTRTC SERVICE SCHEDULE NO. 71 - )
ENERGY EXCHANGE PROGRAM.
COMES NOW the Staff of the Idaho Public Utilities Commission, by and through its
Attomey of record, Daphne Huang, Deputy Attorney General, and in response to the Notice of
Application and Notice of Modified Procedure issued October 20,2015, submits the following
comments.
BACKGROUND
On November 20,2015, PacifiCorp dba Rocky Mountain Power (the "Company") filed an
Application asking the Commission for authority to cancel Electric Service Schedule No. 71, its
Energy Exchange Program. The Company asked that the Application be processed under
Modified Procedure.
Rocky Mountain is a public utility in the State of Idaho, subject to the Commission's
jurisdiction. Application at 1; Idaho Code $ 6l-129.
CASE NO. PAC-E-15.14
COMMENTS OF THE
COMMISSION STAFF
STAFF COMMENTS DECEMBER23,2OI5
Rocky Mountain first offered Electric Service Schedule No. 71, the Energy Exchange
Program, to its customers in 2001 as an optional program "to reduce energy usage as quickly as
possible." Application at2. Customers who wished to participate had to "execute an energy
exchange customer agreement with the Company," under which they would "voluntarily reduce
their electricity usage in exchange for a payment at times and prices determined by the Company."
Id,
Under the Exchange Program, Rocky Mountain notified participating customers "of an
exchange event when market prices were such that it was economic for the Company to encourage
customers to reduce energy usage." Id. In such event - called a "curtailment event" - those
customers "had to maintain their electricity usage below the customer's baseline service for the
duration of the specified event." Id. at2,3.
The program was available only to customers "with a monthly demand exceeding 1,000
kilowatts at least once during the [prior] twelve-month billing period." Id, at2. Participants had
to agree to have a Company-provided meter "capable of recording usage intervals no less than 15
minutes." 1d.
Since its inception, participation in the program has been very limited; eight customers
signed up in 2001 (four in Utah, two in Oregon, one in Washington, and one in Idaho). Id. at2-3.
No customers participated from 2001-2005. Id.at 3. Two Utah customers signed up from 2005-
2008. Id. Since 2008, no customers have participated in the program. Id No curtailment events
have been offered since 2010. 1d
For commercial and industrial customers wishing to participate in the program, Rocky
Mountain offers an Energy Profiler Online ("EPO") energy management product. 1d The EPO
helps customers 6'monitor and more efficiently utilize their energy usage," and a component of the
product is the "load curtailment module." Id. The current EPO contract expires at the end of
2015. 1d Rocky Mountain proposes to "stop purchasing the load curtailment module" of the EPO
program with its new contract beginningin2016. Id.
In support of its request to cancel Schedule No. 7l and the Energy Exchange Program, the
Company cites the limited customer participation since the program began, and the lack of any
customer participation since 2008. Id.
STAFF COMMENTS DECEMBER23,2OI5
STAFT'ANALYSIS
Staff has reviewed the Application and supports the Company's proposal to cancel Electric
Service Schedule No. 71, Energy Exchange Program. Staff investigated three aspects of the
Energy Exchange Program to determine if it should be discontinued. First, Staff evaluated options
the Company currently has available to reduce demand in an emergency. Second, Staff evaluated
historical participation and the number of prior curtailment events. Finally, Staff evaluated the
benefits customers receive from incentive payments and the cost of the program.
Emer gency Demand Reduction
The Energy Exchange Program was initially designed to reduce electric demand during the
Energy Crisis of 2001 , which was triggered by the onset of poor hydropower conditions in the late
spring of 2000. The near-record low runofIin 2001 resulted in almost 4.000 average megawatts
less hydroelectric energy available than in an average year.l Since the exchange program was
designed to mitigate the effects of the 2001 energy crisis, Staff inquired about whether other
emergency demand reduction programs are in place in the event of a future crisis. The Company
responded that it "has two special contracts with intemrption capability in addition to the right to
implement the Inigation Load Control Program as a voluntary event as needed from June 1
through September 30 each year."z In addition, the Company has filed an updated curtailment
plan (Case No. PAC-E-15-10) which includes provisions for emergency load shedding. Staff
believes this combination of resources will provide more effective emergency demand reduction
than the current Energy Exchange Program.
Participation
According to the Company, participation in the exchange program has always been
limited. Eight customers participated during the initial offering in 2001, only one of which was in
Idaho. From 2002 to 2004, the program had no participants until two customers from Utah
enrolled in 2005 before canceling their enrollment in 2008. Currently, there are no customers
participating in the exchange program, and no customers from Idaho have participated since 2001.
I Harrison, John. Energt Crisis of 2000/2001. Northwest Power and Conservation Council, 3l Oct. 2008. Web. l0
Dec. 20 I 5. https ://www. nwcouncil.org/history/EnergyCrisis
2 Company Response to IPUC Data Request 1.
STAFF COMMENTS DECEMBER23,2OI5
Staff asked the Company to describe how participants were solicited for participation into
the program. The Company responded that it "contacted" eligible customers, but did not provide
additional information about its recruiting efforts or the reasons customers gave for declining to
participate. Staff believes it is possible that participation could have been higher by changing
some aspects of the program. However, the fact that only one Idaho customer has ever
participated in the cuffent Exchange Program leads Staff to believe it has little if any value for the
Idaho service territory when compared to the Company's other options for emergency curtailment.
Staff also asked about the number of curtailment events offered to customers during the
crisis, as well as in the decade following the crisis. The Company explained that in 2001, there
was only one curtailment event. Otherwise, there have not been curtailment events offered to
Idaho customers.
Customer Incentives and Program Costs
Staff investigated the benefits customers received from the incentive payments, and notes
that the incentives or 'exchange credits' were provided based on an 'hourly credit rate' multiplied
by the customers' 'exchange amount' during an event. The hourly credit rate is determined by the
Company, while the exchange amount is the difference between the customer's baseline service
level and their measured load for each hour during the event. Staff further notes that the program
includes a minimum hourly credit rate ranging from 3.s$lkwh to 7f,lkWh, determined by the
notification time required by customers before an event.
To better understand benefits the Idaho customer received from incentives, Staff requested
documentation regarding the curtailment event in Idaho, and the exchange credit provided for the
event. The response from the Company states that the Idaho participant received a total of $9.66
for their participation in the event. This is the only incentive for the program in Idaho over its 15-
year implementation.
Staff also assessed the costs of the Exchange Program by requesting information regarding
the Energy Profiler Online (EPO) energy management product. More specifically, Staff inquired
about the cost of the EPO as well as the load curtailment module. According to the Company, the
arurual cost for the EPO is $85,428 per year, with the load curtailment module accounting for
$19,908, or 23%o of the total cost. Staff notes that by discontinuing Schedule 71, Rocky Mountain
Power customers will receive system-wide annual benefits of $ 19,908 annually.
STAFF COMMENTS DECEMBER23,2OI5
RECOMMENDATIONS
After careful examination, Staffrecommends that the Commission accept the Company's
Application for authority to eancel Schedule No. 71, Energy Exchange Program.
Respecttully submitted this ??C day of December 2015.
Technical Staff: Mark Rogers
Stacey Donohue
Donn English
i:umisc:commentVpacel5. l4djhdesdmr commcnts
STAFF COMMENTS DECEMBER 23,2015
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 23'd DAY OF DECEMBER 2015,
SERVED THE FOREGOING COMMENTS OF THE COMMISSION STAFF, IN
CASE NO. PAC-E-I5.14, BY MAILING A COPY THEREOF, POSTAGE PREPAID,
TO THE FOLLOWING:
TED WESTON
ID REG AFFAIRS MANAGER
ROCKY MOUNTAIN POWER
I4O7 WEST NORTH TEMPLE STE 330
SALT LAKE CITY UT 84116
E-MAIL: ted.weston@pacifi corp.com
DATA REQUEST RESPONSE CENTER
E-MAIL ONLY:
datarequest@pacifi corp.com
WONNE HOGLE
ASSISTANT GENERAL COLTNSEL
ROCKY MOUNTAIN POWER
1407 WEST NORTH TEMPLE STE 320
SALT LAKE CITY UT 84116
E-MAIL: [e-mail]
CERTIFICATE OF SERVICE