20240319Decision Memo.pdf

DECISION MEMORANDUM 1
DECISION MEMORANDUM

TO: COMMISSIONER ANDERSON
COMMISSIONER HAMMOND
COMMISSIONER LODGE
COMMISSION SECRETARY
COMMISSION STAFF
LEGAL

FROM: ADAM TRIPLETT
DEPUTY ATTORNEY GENERAL

DATE: MARCH 19, 2024

SUBJECT: IN THE MATTER OF ROCKY MOUNTAIN POWER’S APPLICATION
FOR APPROVAL OF ADJUSTMENTS TO THE IRRIGATION LOAD
CONTROL PROGRAM; CASE NO. PAC-E-24-02.

On January 24, 2024, Rocky Mountain Power, a division of PacifiCorp (“Company”),
applied for approval of certain adjustments to its Irrigation Load Control Program (“ILC”).
Participants in the ILC earn cash incentives for reducing their electric consumption during peak
demand periods. The Company indicated that its contract with Enel X (the third-party
administrator of the ILC) is ending, necessitating the formation of a new, updated contract. The
proposed new, updated contract defines not only the specific services Enel X will perform in
connection with the ILC, but also the pricing for the ILC.
The Company represented that the ILC has changed little over the last decade and
anticipates few changes going forward. However, the Company’s new, updated contract with
Enel X increases the monetary incentives for ILC participants by 30%, with subsequent annual
increases of 2.5% built in. These increases are intended to avert, and possibly reverse, declines in
ILC participation experienced during the last decade. The updated contract also permits the
Company to initiate called events upon two-hour’s notice, rather than the previously required
four hours. The Company requested that the Commission approve continuation of the ILC via a
new ten-year contract with Enel X, effective April 1, 2024.
At the Commission’s February 6, 2024, Decision Meeting, Staff presented a Decision
Memorandum recommending the Commission suspend the proposed effective date to allow
additional time to review the Company’s proposal and public comment.
DECISION MEMORANDUM 2
On February 21, 2024, the Commission issued a Notice of Application, Notice of
Intervention Deadline, and Notice of Suspension of Proposed Effective Date, setting an
intervention deadline of March 13, 2024, and suspending the Company’s proposed effective date
to May 31, 2024. Only the Idaho Irrigation Pumpers Association, Inc. intervened.
STAFF RECOMMENDATION
Staff recommends the Commission issue a Notice of Modified Procedure,
establishing a public comment deadline of April 18, 2024, and company reply deadline of May 2,
2024.
COMMISSION DECISION
Does the Commission wish to issue a Notice of Modified Procedure establishing a
public comment deadline of April 18, 2024, and company reply deadline of May 2, 2024?

_____________________________
Adam Triplett
Deputy Attorney General

I:\Legal\ELECTRIC\PAC-E-24-02_Irrigation Load\memos\PACE2402_dec2_at.doc