20030306Idaho Irrigation Pumpers Comments.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]
Attorneys for the Idaho Irrigation Pumpers Association, Inc.
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BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION
OF P ACIFICORP DBA UTAH POWER &
LIGHT COMPANY FOR APPROVAL OF
AMENDED ELECTRIC SERVICE SCHEDULE)
72-IRRIGA TION LOAD CONTROL CREDIT)RIDER PROGRAM
Case No. PAC-O3-
IDAHO IRRIGATION
PUMPERSASSOCIATION,
INC'S COMMENTS RE:
AMENDED SCHEDULE 72
COMES NOW the Idaho Irrigation Pumpers Association, Inc. ("Irrigators ), through
undersigned counsel, and hereby respectfully submits its comments on PacifiCorp s proposed
Irrigation Load Control Credit Rider Program.
In reaching the settlement in P AC- E-02-, the Irrigators and PacifiCorp agreed that
PacifiCorp would work with the irrigators as a class to develop an optional load control program
for the 2003 and succeeding irrigations seasons. The rationale for the request was to provide an
option for irrigators to reduce their power costs primarily in situations where a significant portion
of an individual irrigator s load did not benefit from the BP A Exchange Credit. The Irrigators
have participated in the meetings that PacifiCorp held on this issue on December 5, 2002 and
January 17 , 2003 and believe that PacifiCorp has worked in good faith to develop a workable
load control program, particularly with respect to the load control conditions. In general, the
Irrigators support the implementation of the optional load control program, subject to the
clarifications or further study requested herein.
IRRIGATORS' COMMENTS RE: ELECTRIC SERVICE SCHEDULE 72 -
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The Irrigators ' primary concern with PacifiCorp s filing is that the methodology for
determining the Load Control Service Credit ("LCSC") has not been flushed out by PacifiCorp
such that a determination can be made as to how the LCSC is determined. As a result, the filing
does not give sufficient information to determine ifPacifiCorp is offsetting the interruption
savings with its projected lost revenue as a result of the interruption. It also does not indicate
whether the LCSC is determined solely on the cost of avoided market power purchases or the
cost of the avoided supply side resource, or some combination of both. The filing also provides
PacifiCorp with the discretion to arbitrarily set the separate components of the LCSC, e., the
participation portion and the kWh portion, at zero for any given year. This makes it very hard
for an irrigator to determine what the long-term benefit would be from participating in the
program, especially if he has to initially invest in acquiring the necessary load control devices.
The Irrigators recommend (1) that some base participation credit be set under the program such
that the irrigators could better quantify the minimum benefits of participating in the program
from year to year and (2) that further information be provided as to how the value of the
interruptibility credit is determined such that the Irrigators can further address this point before
the Commission in light of the principals recently established in PAC-01-16.
Another concern with the filing is that there is no information provided by PacifiCorp as
to what the terms and conditions of the Load Control Service Agreement will be. This needs to
be reviewed by the Commission and interested parties to ensure that said agreement is
understandable and fair to all the parties.
The filing also seems to indicate that there will be additional costs, in the form of new
load control devices, incurred by the irrigators in order to participate in the program. It is the
Irrigators' understanding that the necessary load control devices should , for the most part
IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.S POST-HEARING BRIEF - 2
already be in place. Thus, PacifiCorp needs to clarify whether it is requiring new load control
devices, and if so, why such devices are considered necessary for the operation of the program.
Finally, the Irrigators believe that a review of the actual benefits of the load control
program should be conducted annually. This will allow the interested parties to assess
participation from the irrigators and quantify the benefit to PacifiCorp and its customers. Thus
the Irrigators would recommend that an annual review provision be included in the program.
In conclusion, the Irrigators believe that the proposed load control program can provide a
valuable demand side resource to PacifiCorp, as well as a valuable cost saving measure for the
Irrigators, if the terms of the program are further refined so as to allow adequate participation.
The only way to have adequate participation is by appropriately pricing the credit for
interruptibility. Further information is clearly needed for the Commission, the Commission
Staff, and the Irrigators to thoughtfully make such a determination.
Respectfully submitted this 6th day of March, 2003.
RACINE, OLSON, NYE, BUDGE &
BAILEY, CHARTERED
L. SEN
Attorneys e Idaho Irrigation Pumpers
Association, Inc.
IRRIGATORS' COMMENTS RE: ELECTRIC SERVICE SCHEDULE 72 - 3
CERTIFICATE OF MAILING
I HEREBY CERTIFY that on this day of March, 2003 , I served a true, correct and
complete copy of the Idaho Irrigation Pumpers Association, Inc.'s Comments Re: PacifiCorp
Irrigation Load Control Credit Rider 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
Boise, Idaho 83720-0074
E-mail: jjewell(0puc.state.id.
Hand Delivery/E-mail
Doug Larson
PacifiCorp
201 South Main, Suite 2300
Salt Lake City, Utah 84140-0023
Soda Springs, Idaho 83276
S. Mail
IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.S POST-HEARING BRIEF - 4