20101129Mickelsen Sur Reb.pdf

Î
Q BEFORE THE IDAHO PUBLIC UTILITIES COMMSSION
IN THMATTR OF THE APP.LICATION )
OF ROCKY MOUNAI POWER FOR )
APPROVAL OF qRGES TO ITS )
ELECTRC SERVICE SCHEDULES AND A )
PRICE INCREASE OF $27.7 MILION OR )
APPROXITELY 13.7 PERCEN )
RE'CEl\1
21Humv 2 9 r~M 10= ~ 0
CASE NO. PAe-E~I0-7
IDAH IRGA nON PUMPERS
SUR REBUTAL TESTIMONY
OF
MA MICKELSEN
NOVEMBER 29, 2010
I Q.PLEASE STATE YOUR NAM, ADDRESS, EMPLOYMNT, AND
2 AFFILIATION WI TH IDAHO IRIGATION PUldERSASSOCIATlON, INC.?
3
4 A.My naie is Mri Mickelsen, and I am the president of the Idi Itg.ÛQt
S Pupe Association, Inc. ("lI A"). I fanin the Osgooarea of BonnevìIleCounty, Icho.
6 My tldress is 9088 N. River Road, Idao Falls, Idahö 83402. I curently grow potatoes,
7 whe.t, ard canola,and my faning operations are principally served by Rocky MOllta
8 Power ("RMP").
9
10 Q.WHT IS THE PUROSE OF YOUR TESTIONY?
11
12 A.The purse of my testimony is to address the proposed chages to the
13 Irgation Load Management Progr and the Agrcultual Energy Savers Progran conwued
14 in the Rebutt Testmony of Carol L. Hunter.
is
16 Q.WHT INOLVM HAS TH IIPA HAD IN TH DEVELOPMENT
17 AND IMPLEMENTATION OF RMP'S IRGATION LOAD CONTROL PROPGRAMS?
18
19 A.As par of the settlement in PAC~E~02~01, IIPA and RMP agr to develo
20 an optionlloa.d mwgement prognin consideration for the remval of the log stadin~
21 interrptble irgation rae scheule C and it associated load control beefits. 11s ti~
22 9ase program started()t smal, but continued to grw duetocoutIuous retinenent by
23 RM ånd IIA,as well aslIA's strong encóllgeit ófits melîbers. to ~icipatein the
i Mickelsen Sur Rebu
hrgator
I program. Eventually it provided in exces of 40MW ofloaet reuctionto PacifCor' s
2 system durng the surer moths. The curnt version of this timr pasØptogn can be
3 found in RMP's Electrc Servce Rae Schede No. 72.
4 In 2(), lIP A woied with RM in the deveiopment of the .tenns anconditØt of a
5 dispaichable load control pilot prgr. Ths program was a vast improvement for.ii
6 involved in tht the irgation pumps were curled ditectly by R. (at its option) vìa .
7 coniunications device rather than a tier. The pilot progr wa.ssuccessful, in pa, due to
8 IIPA ~s input and Ilateting efforts amóngst its members. As par Qf the selemt inPAC~
9 E~7-oS, RMP and IIPA agreed to an increase in the creit for the dispatchableprogrbased
10 on the level of irrgator paicipation for the 2008 aid2009 irrgation seasns. lfirrgator
1 1 partìcipatìøn reached a certin level then the credt would be .adjustee accordingly, as
12 follows:
13
14
15
16
ParcÌQtìoo MW
Less than 150
150 to 175
175 or greater
Crt (S/W ~yr)l
$23
$26
$28
17 Due to IIA'said RMP's niareting effort, Irgator paricipation ii the dispatehable
18 progr signficantlyexceed expetaions, and in 2010 achieved and estimated 278 MW
19 of paricipation in July2 at the saes leveL. This estimated figiedoes not count those
20 participants in the tiner progr.
21 In the faii of 2009, IIPA and RM had ñierdiseusions regardig ìnprovettit$to
22 the tenns of'thedispatchable proilam and the credit amotlt to be paid. Thes discsio
23 resulted in a LeUer Agreement betwee RM and lI A makg chages to the temi óftbe
24 dispaichable progr and extending the curent pricingand paìcipatio schedule tb$h
2 Mickels Surlt~Irlat
1 the 2012 irrgation season. A copy of the Leter Agrent i~ Ilttached hereto as Exhibit 304..
2 NoW the dispatchable progran alone consistently provides Over 250 .M ofloa redctonttï
3 PaCifiCorp's system per control event. The curnt verion of ths dispatch able progr ca
4 be found in RM's Electrc Service Schedule 72A.
5
6 Q.DO YOU PARTICIPATE IN RM'S LOAD CONTROL PROGRAMS
7 AN WH?
8
9 A.Yes. I have paricipated in RM's loadcontrol progrs for the last fou
10 irrgåtion seasOnS under the dispatChable progr. I did not piuc:pate in the tìierhase
11 program beaUse credit amount received did not exceed my opportity costs ()finç~~
12 labor expens and reduced crop yìelds. I continually etoourge all eligibleitgatotsto
13 paricipate in RM's load control programs, and I and other members of the lI A'ji board
14 have invested a significant amount of tie working with RMand nPA's members to mae
15 the load control programs successfuL. This is based not only for the crt saVÌngS, Which has
16 beeoIl crucial to many faners in these UIcerain economic tines, but also for the befits
17 of reducing RMP's overall system cOS, the Idao jursdictional costs, and theirrgatOts'
18 class cost of servce..
19
20
1 Subjec to a Si.OO adjustment ~ot down dendiD8 00 RMP's fina valution of th befit.
2 BasedupoRM's response to Irgation rest 23.
3 Micke~ Sur ReutIrgat
I Q.PLEASE SUMMAE RM'S PROPOSED CHAGES TO THE
2 DISPATCHALE LOAD CONTOL PROGRA?
3
4 A.In light of the jusdictonal cost alloction and fudig issues raise Ùl
5 thiscll, RMP ha propose to reuce the magntude of the progrlU and ultintely
6 the costs associated with the dispachable loaet contrl progtân ("Ptógr") by (1)
7 restrctng parcipation in the Program to irgation Pumps of at least SQ HP, (2)
8 provìding RM flexibì1ty to rejector naow the parcipants in the Progm (3)
9 increaing the penalty a paricipant faces in the event the irrgator opts out of
10 paricipatig in a load control event, (4) reducing the paricìpatin-credtforth20ll
1 i irrgation season from $30 per kW to.$2S per kW, (5) havìngthe administrûve costs
12 of the Progr remain situs assigned for the 201 i irrgation seon and havìg RM
13 and Staff work to address the issues of system cost allocation of the .dministrtive
14 costs of the Program in the MSP process for 2012. RM has ha recent etsc\lsions
15 withII A's board regaetng these proposedchanges.
16
17 Q.WHT CONCERNS DOES THE IIA HAVE WIT RMP'S
18 PROPOSED CHANGES TO TH PROGRA?
19
20 A.Just like the major capital investments that RM is now seeking tö
21 place into rate base, the irrgation load contrl progrs ar a cumination of ye of
22 effort, planng, tral and error to bring them to the cost efectiveand.sucessfu point
23 they are at this time. RM'sptoposed changes are aimedAt cuttingPlogr cost ny
4 Mickelsen Sur Rebutt
Irgators
1 shring irrgator paricipatin and, in the near ter reducing the credit amunt pad
2 to Paricipants. However, IIA'sböd believes thatevet if thes ar consider to
3 be short term chages, they wil have long term detrental effec beause
4 confdence in the progr may be lost.
5
6 Q.WHT LONG TERM EFFETS WOULD BE EXPECTE?
7
8 A.For example, restictng parcipation in the program to 50 hp will
9 reniove 500 control unts accordng to the Company. Ths may only mean .
10 reduction of 13 MW ofpåricipaton, but to put this in perspeive, there were les
11 than 2,00 parcipating sites in 200. This chage would impact over 25% oftli
12 paricipating sites. Ths propsal is being mae in spite of the fac th these devies
13 are ctintly in place anet the cost of instalation ha already ben expensed if not.il
i 4 ready reovered by RMP.
15 Additionally, this proposal is inconsistent with the cuent tRrff langue
16 whihståtes:
17 Once a LCSA is executed, Customers in the PfO will be
18 consietered progr parcipats for subsequent yea uness the
19 Customer explicitly communates the deite to no longer
20 parcipate in the Lod Contrl Credt Rider.progrorthe progr
21 is cancelled. (Emphasis added)
22 FurerQre, givìng RM the flexibilty to rejec cuent parcrpts at will puts the
23 progr in even I1Qrejeopary. How is RM going to restrPacipation?WiU it
24 be On a fit~ome-fit~served bais? Whtabout all of th cutome thtue
5 Mickelsen, Sur Re
ItlatOf
1 presentlyon the progre they first in line? Wht about the cles that
2 irrgators had ma.etothei sYSems so th tley could pacipate in the program?
3 The chages in the opt~ut provìsions may sound go in isolation. but the
4 fact is that there aree)ttremely few paricipants tht opt-o at ths Ûme. Furerre,
5 each time a cutomeropts~ut, he pays the maginal purhae cost for the power he
6 consuesand the system is nide whole at the higheSt purchase powercòt. The
7 ominous penalties being propod ca only result in scrrng irgators away from
8 paricipating in the progr.
9 The LIP A is disappointed that ltMP is not going to live Up to its agreemet to
10 keep the pricing oftlepartcipation credit the sae though 2()12 as set fort in the
i 1 Lettr Agreement. We tliituly came up with a 3~ye agreement only a year.gQ
12 and now RMP wants to unilaterally lower the credt. If the credt flucttes, wht
13 assuranCe dQirgators have that the progr will continue to beefittlem in th
14 futue and that they should put forth the time and investment to parcipte in tle
15 progr?
16
17 Q.WHT AR YOU ASKIG TH COMMISSION TO DO AT TØIS
18 TIME?
19
20 A.The Commssion nee to balance how these diaiges wil affect th
2 I continued long term vìåbiltyof the irgation load controlprograndnot
22 jeopardie the prir investments in time and effort tht havem-ought us to this pØint.
23 Such a detennintion procss is iJpossinle to eto in the ver copresSt'rebu
6 Mickelsen, Sur Rebutt
Irgators
1 testimony and subseuent techncal heang schedule in ths cae. Thu.$, the lI A
2 llk$ the COIlission to nif\caie the consideration of the Prog changes fr()tt dii$
3 cas so tha RM, Sta, IlA,and other interested pares ca mor fuly vet thes
4 issues in.expedited maer, without unintentionally affecûugtbe long tevìability
5 of the irgation load control progr.
6 In the event that the Commission is inclined to tldr$ssubsttíVe cbges to
7 the Progran initsfotthçoining Order, then the nPAha the folløWig commeiitS øii
8 RM's proposed chanes to the Progr:
9 . First, the IlA is not oppose to retrctig futue parcipation in the
10 Prognto pumps having a minimum of 30 HP. This chae appea tha.t
11 it would not have a significant effect on the tota ait ofMWs of
12 PrOgr parcipation and should reuce the equipmentex~nses.
13 However, like Icho Power, smaller Irrgators could pacipate if they pay
14 an intallation fee. There is no benefit togo back to these customers tht
15 presently haves. control device and inCur f\er costs to reinove these
16 devieesaret .iiic"tng any accopaying. il-wil.
17 . Seçond, the IIA supports in the inclusion of the Ieto Power
18 parcipation selecton languge so as to give RMP flexibility in effciently
19 administeng th Prgrm. However, this flexibility shoud Qtlybe
20 applied to futue instalaton and any rejecon of a cutor should have
21 wrtten justificatÎii. It is my undetadig thateveii thougl ldao Power
22 has this flexibilit, it has neverexercise it. We do not want to give
7 Mickels S\lRebllt
Irsatot
1 lange like tht in Idao Power's taff and have it be used in a
2 completely different way by RM.
3 . Thitd, the I1A i$ not opposed to changes to the penaty for op-out ,vents
4 under Schedule 72A. IIA believes that the amouJtofåvoide lóå
5 should be there when caled upon and that the penalty change should help
6 avoid frt~e-rider cOncern. However, the penalty Proposed by RM is
7 excessive, Idah Pøwer ha a fleet opt-out feeof$O.OOS per kWh of
8 l1ónthlybillig. The IiA beHeves that ths amount is sigtficant, but we
9 would be willng to accept it for use in RM. Anything beyond ths would
10 seriously jenarcl the pn,lgr.
i i . Finally, the IIA Objects to RMP's propsal to reduce the credtuiount
12 under the Prgr from $30 perkW to $25 per kW for the 201 i irgati
13 seson. One of the keys to the success of the Prgr wassetùig th
i 4 credt at an amount thåt would be cost effective, i.e., the befits excee
is their costs under respeve regutory tess, but alsoencoumge siicìent
16 irrgator parcipation notwithding the irgators' .opportty costs of
17 increased labor expese and prospets ofreducedcrop yields. This is why
18 the IIA entered into th Letter Agrment to provide tht credt certiity
19 to parcipants and associated parcipation so as to mainwnthsvable
20 system deid..side resouce. The IIPA believes thtRM should live up
21 to its obligaÌ(ns under the Lettr Agreeent an tht the crt _inount
22 should remanat its cuent $30 pe kW level for the 201 1 ån 2012
23 irgation seOns.
8 Mickelsn,S. R.~Irgat
I
2 Q.WHT is TH lI A'S POSITION ON THE PROPOSED
3 ELIMINATION OF TH AGRICULTUL ENGERGY SAVERS PROGRA?
4
5 A.The IIA understads tht the Agrcultul Energ Savers PrOgr is
6 not as cost effective as the load control pr08tam, but points out t1î it stìI is
7 considered tóbe C(st ~ffecve. The lI A IÙSO acknowledge$.that a signficant poon
8 of energy effciency and load inangement dollar ar sPnt for the agrcultu seor
9 programs. However, the UPA believes tht this potential imbalance is not the result
10 of any bilŠ, but justa. fuction of gettng the more bang for ever buck spton
1 1 irrgation program as oppose to otherprograis cuently avaìlable to thecllstomer
12 classes. Neverteless, the lIA would defer to the judgment of the Commission as tö
13 whether the Agricultuiù Energy Savers Prgr is elìminated or not inoreter to
14 reduce energy effciency and demand side mangement costs.
15
16 Q. DOES THIS CONCLUDE YOUR DIRCT TESTIMONY?
17
18 A. Yes.
9 Mickelsen S1l.Rebu~Irlat
lt~itt(..t'!~:iv~~*~~'f
Jeffrey K. LIrselt
Vice President, Regulation
Om! Utah Center
201 S. Main Stree, Suite 2300
Salt LIte Cit, UT 114111
801.220.4907
ROCKY MOUNTAINPOER
October 15,2009
Idaho Irrigators Pumper's Association
201 East Center
POBox 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 purpse of this letter agreement is to memorialize the October 6, 200 discussions
between representatives of Rocky Mountain Power ("Company") and the Idaho Irrgation
Pumper's Association, ("IIPA"). The Company and IIPA collectively are referred to herein
the "Parties". At that meeting, the Parties discussed the results of the dispatchable irrigation
progra to-date and negotiated the post-2009 terms of such program.
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 Utilties 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 Parties have agreed to the following changes in the terms and conditions
of the dispatchable IiTIgation prograni under Tariff Schedule 72A to address the post-2009
treatment of the program:
I. extend the current paricipation schedule for the irrigation seasons though th end of the
2012 irrgation season;
2. revise the dispatch program season from the ClUTent period of June I to September 15 to a
new period of June 1 to August 31 of each year; and,
3. revise the available dispatch hours frm the current period of 2:00 PM to 8:00PM to a
new period of 11:00 AM to 7:00 PM. The change in times will help faciltate phing in
and Out of dispatch events as well as provide additional time to the pumpers to check tht
their irrgation system is operating correctly before it gets dark;
exib No. 30
CaNo.PAC-E-1Q.7Mi..lr
Furtermore, 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 attched tariff sheets. The Parties 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.
rey K. Larsen
Vice President Regulation
The Parties 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.
ER
Date:/lJlçøt~Te
r ¡dent Regulation
2 1 uth Main Street, Suite 2300
Salt Lake City, DT 84 i 11
IDAHO IRRIGATION
PUMPER'S ASSOCIATION
By:
Eric
Attorney for lIP A
201 East Center PO Box 1391
Pocatello, il 83204
Date:
Exhibit No. 304
Case No. PAC-E-10-07
Mickelsen, Irrgators
4. revise the available dispatch hour from the curent period of 2:00 PM to 8:00 PM
new period of 11 :00 AM to 7:00 PM. The change in times will help faciltate phaing in
and out of dispatch events as well as provide additional time to the pumpers to check that
their irigation system is operating correctly before it gets dark; and,
5. continue to provide results of the Dispatchable Irgation program in the DSM report fied
anually with the Idaho Commssion.
Furermore, the Pares agree to these tenns and conditions as reflected as revisions to the
current Tariff Schedule 72A, with all other terms and conditions remaing unchanged as
specified in the attached tariff sheets. The Parties wìl support these changes to Tarff Schedule
72A in a Tarff Advice fiing made by the Company for Commission approval and represent that
they are in the public interest.
,/,..
J yK. Larsen
Vice President Regulation
The Paries have negotiated the changes to taff Schedule 72A in good fàith and by their
signatues below acknowledge and agree to the terms as detailed above.
ROC MOUNTAI POß
By: i:- Date:
Jeff
Vi20 ai Stret, Suite 2300
Salt Lake City, UT 84111
/ob1129i i i
IDAHO IRRGATION
~
Attorney for II A
201 Eat Center PO Box 1391
Pocatello, ID 83204
Date: /tJIZóß9
ExNo. 30
Case No.PAC~ 1 Q.1Miel,lr
,.~ ROCKY MOUNTAINPOR
A OlVSlON OF PAFI
I I.P.U.C. No.1
l'hiFdFounh Revion of Sheet No. 72A.l
Canceling SeeøfldThird Revblon of Shee No. 72A.l
ROCKY MOUNAIN POWER
ELECTRIC SERVICE SCHEDULE NO. 72A
STATE OF IDAHO
Dispatchable Irrgation Lod Control Credit Rier Proram
PURPOSE: This optional tariff allows Customer to participate in a dispatehable cotrl service
interruption program in exchange for a Load Control Service Credit (LCSC). Customers partcipaing in this
progrm wil be considered participants in the Irrigation Lod Control Creit Rider progrm.
PARTICIPATION: Prior to paricipation, and in orde to qualitY under this Scheule, Cusomers
must execute a Load Control Service Agreement (LCSA) with the Company. Participants in the tlisptehable
prgram wil be considered progrm paricipants for subseuent yea unless the Customer explicitly
communicates the desire to no longer paicipate in the Load Control Credit Rider progrm.
APPLICABLE: To qualifYing Customers served on Schedule 10 an who have cotinuos acss
to the Internet from May i through September 15. Access to the internet beginning May t is reuire to
allow for program information sharing, training, and communication testing in advance of the contrl
season. In addition, Schedule to Customers participating in the dispatchable program must:
(a) Meet minimum irrigation equipment motor lod size of30 Hp. The Company may evaluate
individual pumps or motors smaller than 30 Hp to determine if paricipation is co-eecive or
necssary beause such pumps are pal1 of a larger participating system.
(b) Use advanced 2-way remote control equipment as specifIe by the Company to maRage ALL
pumping reuirements throughout the Company defined Irrigation Seson (June i though
September 15).
( c) Participate in Company..efined training to set \l their pump sites for dispah.
(d) Incur air time communication charges for communication transactions exceing 70 per month.
Charges for communication transactions in excess of 70 per month wil be dedcte fro th
Customer's LCSC.
This rider
(Continue)
Submitted Under Advice No. 09-05+
200 EFFECT: JUReDecember t, 200ExNo.*
c. He. PAC~1N1Miel. ..
~~ROCKY MOUNTAIN
POWER
A DIVSI OF PAICOIP
I I.P.V.C. No.1
ThirtFollrtb Reviion of Sheet No. 72A.2
Canceling 8eeaødThird Revion of Sheet No. 72A.2
ELECTRIC SERVICE SCHEDULE NO. 72A - Continued
LOAD CONTROL SERVICE AGREEMENT: The Customer and Company wil execute a LCSA
for irrigation load control participation. The LCSA shall specify the Load Control kW amount that each of
the Customer's sites shall curtail during each Dispatch Event. The agreement wil also include typical costs
that the Customer may incur for Ealy Termination. Once executed, the agreement shall remain in force for
subsequent Irrigation Seasons unless explicitly canceled by the participating Customer. Cancellatin of an
existing LCSA may occur only between September 16 and May 30 each year.
LOAD CONTROL SERVICE CREDIT: The LCSC fòr a paricipating site shall be calculated and
issued to the participating customer in the form of a check, or as a credit against the participating site
account if an outstanding account balance exists that is 30 days or more past due two weeks befor the creit
issuance. The LCSC wil be issued no later than October 3 i following each irrigation season. Th LCSC is
composed of a Fixed Annual Participation Credit that shall remain fixed throughout the liTigation Seso
each year. The LCSC shall be computed at the conclusion ofthe Irrigation Season by multiplying the Fixed
Annual Participation Credit times the Load Control k W at the Schedule i 0 metered pump site. The Lod
Control k W shall be computed by taking the most reent 2-year demand (kW) average for that paricular site.
In situations where the pump has ben replaced and/or re-wound the kW shall be computed by taing the
manufacturer's revised nameplate Hp and converting it to kW using standard engineering conversion
metrics.
The Fixed Annual Paricipation Credit for 20 i 08. 20 I i and 20 i 200 is based upon total program paicipation
volumes as defined in the table below (Participation Credit Schedule). The participation credit is inreed
for each tier of program participation volume to encourage participation in tbe program.
Participation Credit Schedule
~~
Pårticipatit. CreditProgramPatticipatiotl
VQlll1lcs (MW)($/kW..yr)
Lesstban I 50 $23.00_.
$26.00150toless than 1 75
175 or greater $28.00
SCHDULE:
Notificatin of Credit: The Company wil provide notification of the total LCSC to aU eligible
Schedule i 0 customers by Februar 15 eah year.
Load Control 8erviee Agrement: Concurrent with the Notification of Credit referenced above, th
Company wil provide a LCSA listing the amount of the creit the Customer wil reive 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 participate in this load control program shall sign the LCSA and return
it to the Company by April 15 to indicate their paicipation.
(Continue)
Submitted Under Advice No. 09-05
ISSUED: f'ebrnaryOctober ++22, 2009 EFFECT:. Ex
CaM No. PAe-~10-7Mils, In
"~ROCKY MOUNTAINPOER
A DIVSION OF PAFlP
I I.P.V.C. No.1
Thin:Fourth Revision of Sheet No. 72A.
Canceling SeeeodThird Reviion of Shet No. 72A.3
ELECTRIC SERVICE SCHEDULE NO. 72A - Continued
DISPATCH CONDITIONS: The Compay shall have the right to implement a Dispatch Event for
participating customers according to the following criteria:
(a) Available Dispatch Hours: ;;11:00 l!AM to 87:00 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 (I) Dispatch Event per day
(e) Dispatch Days: Monday through Friday (inclusive)
(t) 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.
SPECIAL CONDITIONS:
Load Control kW: The Load Contrl kW amount for the ;;007 Irrigation Season shall be computed
as follows:
1. The maximum kW for the past two (2) year (or available history) for each ofthe four irgation
months shall be averaged 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 creit as defined
in the Participant Credit Schedule above.
Outages: Uncontrolle outages or other types of interrptions do not qualify for payment under the
tariff.
Ownership of Contrl 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 lol 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 irrigation control equipment is pennitted.
The cost of such trnsactions wil be the Customer's respnsibilty but wil be managed through the
Company (Note: Customer air time communication costs, if any, wil be calculated as a reduction to the
LeSC).
. Liquidated Damages: Customers are pennitted to 'opt-out' of five (5) Dispatch Events thrughout
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 progrm's call center, or by notifying a program field technician.
Each 'opt-out' event wil incur a cost reulting in a reduction to the Customer's LeSC. The cost wil be
calculated bad on the $IMWh the Company otherwise has to pay for power at the time of the Dispatch
Event. Such SIMWh prices wil be provided by day ahead on-pek price as published at http://theice.com
and wil be basd on the estblished Four Comers trading hubs.
(Continued)
Submitted Under Advice No. 09-054-
ISSUED: FebraryOetober ++22, 200 EFFECT~ià~c?';1fber 1,200
Case No. PAe-.1Q.7Miel, ir
~ROCKY MOUNTAINPOER
A OIVl Of PAClFlCORP
I i.P.U.C. No.1
ThiFdFourth Revion of Sheet No. 72Â.4
Canceling SeeomiThird Revison of She No. 72A.4
ELECTRIC SERVICE SCHEDULE NO. 72A - Continued
Liquidated Damages: (continued)
'Opt--uts' wil be computed at the conclusion ofthe irrgation season and wil be included as a
reduction to th LCSC payment issued to the Customer prior to October 3 I each year. 'Opt-ots' beyond
those identified above are not permitted. Violation of the Liquidated Damages provision shall result in Early
Termination under the tenns of Special Condition-Early Tennination, foifeiture of the entire LCSC.
Liabilty: The Company is not resposible for any consequences to the paicipating Cústomer that
result from a load control Dispatch Event or the failure of load contrl equipment.
Use of Load Control Equipment: Th Customer shall be required to exclusively use the 2-way
load control equipment to manage their irrgation equipment through the duration of the Irrigation Season.
Load Sbiftng: Customers participating in this program may not shift irrigation loàds to oter
facilties served by the Company or purchase replacement production from another facilty served by the
Company. The Company reserves the right to determine if the participating customer site is in violation of
Special Condition-Load Shifting. Violation of the Load Shifting provision shall result in Early Tennination
under the terms of Special Condition-Early Termination, forfeiture ofthe entire LeSC, and removal from the
program for the remainder of the Irrigation Season.
Control Equipment Damage I Sabotage: The Company reseres the right to detennine if load
control devices were intentionally damaged and/or bypassed to limit load control. Violation of this clause
shall result in early tennination under the tenns of Speial Condition-Early Tennination, foifeitute of the
entire LCSC, and removal from the pilot program for the remainder of th Irrigation Season.
Early Termination: If the Customer is terminated from the progm thè Customer shall be
responsible for reimbursing the Company for costs asciated with participation in the program. Such costs
include, but are not limited to, direct and indirect labor costs asociated with enrollng the Customer in the
progrm, labor costs for installng the equipment, labor to investigate intentional damage to loa contrl
devices, removing the Customer from the program, and wil not include costs for replacement power.
Customers required to pay costs associated with early termination under tenns of this Special Condition will
be provided with a statement detailng such costs.
Fre Riders: Customers may not participate in this progr with accounts and mèter that woold
not have used power during the Irrigation Season irrespetive of participation in the progrm. The Company
reseres the right to detennine if the participating customer is in violation ofthe Special Condition-Fre
Riders. Violation of Special Condition-Free Riders shall result in Early Tennination, forfeiture ofthe LeSC,
and removal from the progrm for the remainder of the Irrigation Season.
ELECTRIC SERVICE REGULATIONS: Service under this Scheule wil be in acco with
the terms of the Electric Service Agreement between the Customer and the Company. The Electric Service
Regulations of the Company on file with and approved by the Idaho Public Utilties Commission, including
future applicable amendments, wil be considered as foring a part of and incorpated in said Agreent.
Submitted Under Advice No. 09-0+5
200 EFFECTIV: JUReD
Ex No.
Ca No. PAC-.10.7
Micel. ll'
er ll 200