20230223Comments.pdf

IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.’S INITIAL COMMENTS – Page 1
CASE NO. PAC-E-22-13

Eric L. Olsen (ISB# 4811)
ECHO HAWK & OLSEN, PLLC
505 Pershing Ave., Ste. 100
P.O. Box 6119
Pocatello, Idaho 83205
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail]

Attorney for Intervenor Idaho Irrigation Pumpers Association, Inc.

BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION

IN THE MATTER OF THE APPLICATION
OF ROCKY MOUNTAIN POWER FOR
AUTHORITY TO IMPLEMENT A
COMMERCIAL AND INDUSTRIAL
DEMAND RESPONSE PROGRAM

CASE NO. PAC-E-22-13

IDAHO IRRIGATION PUMPERS
ASSOCIATION, INC.’S INITIAL
COMMENTS

COMES NOW the Idaho Irrigation Pumpers Association, Inc. (“IIPA”) and pursuant to
Commission’s Order No. 35662 and provides its initial comments regarding Rocky Mountain
Power’s (“RMP”) petition for authority to implement a Commercial and Industrial demand
response program.
I. COMMENTS
RMP proposes to add a business demand response program to its Idaho tariffs (the
“Program”). The Program will be offered to customers with greater than 500 kW of load curtailable
with under 7 minutes of advanced notice. This program is available for both manual curtailment
and automatic curtailment responses.
Upon review of RMP’s application, IIPA generally supports the application. However,
IIPA offers a few comments for consideration by the stakeholders. First, IIPA is concerned that
the incentive and curtailment parameters are not clearly specified. Second, IIPA is concerned
that the cost responsibility for enabling equipment is not specified.
RECEIVED
2023 February 23, 4:10PM
IDAHO PUBLIC
UTILITIES COMMISSION

IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.’S INITIAL COMMENTS – Page 2
CASE NO. PAC-E-22-13

Incentive and Curtailment Parameters
The tariff specifies an upper bound for incentives and dispatch hours. However, RMP
appears to intend to provide more specific incentives and dispatch limits through its website.
RMP has also indicated that these values may change over time at RMP’s sole discretion without
triggering any form of tariff filing or update. This is concerning to IIPA because there is a
relationship between curtailment hours, incentive rates, and Program cost effectiveness. While
the Program may be cost effective under RMP’s modeled parameters, the Program could easily
become not cost effective under alternate parameters. IIPA understands there may be some value
in retaining flexibility for this Program. However, IIPA recommends that the tariff be modified
to ensure that the flexibility remains within the set of parameters that are cost effective.
Alternatively, RMP could include ongoing cost effectiveness tests as part of a Program annual
reporting requirement.
Company Installed Equipment
RMP’s application indicates that control equipment or notification equipment may be
installed on the participant’s premises. However, it is unclear which party is responsible for
installation costs. IIPA recommends that the responsibility for equipment cost, including
maintenance, be clearly specified.
II. CONCLUSION
Notwithstanding the concerns stated above, IIPA is generally supportive of the proposed
program and believes it could provide a valuable demand side resource. However, IIPA
anticipates that other parties may raise issues in opening comments that IIPA has not considered,
and such issues may modify IIPA’s position on the filing.
DATED this 23rd day of February, 2023.
ECHO HAWK & OLSEN
_____________________________________
ERIC L. OLSEN

IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.’S INITIAL COMMENTS – Page 3
CASE NO. PAC-E-22-13

CERTIFICATE OF SERVICE

I HEREBY CERTIFIY that on this 23rd day of February, 2023, I served a true, correct and
complete copy of the Idaho Irrigation Pumpers Association, Inc.’s Initial Comments to each of the
following, via U.S. Mail or private courier, email or hand delivery, as indicated below:

Jan Noriyuki, Commission Secretary
Idaho Public Utilities Commission
P.O. Box 83720
Boise, ID 83720-0074
[e-mail]

U.S. Mail
Hand Delivered
Overnight Mail
Telecopy (Fax)
Electronic Mail (Email)

Michael Duval, Deputy Attorney General
Idaho Public Utilities Commission
11331 W. Chinden Blvd.
Building 8, Suite 201-A
Boise, ID 83714
P.O. Box 83720
Boise, ID 83720-0074
[e-mail]

U.S. Mail
Hand Delivered
Overnight Mail
Telecopy (Fax)
Electronic Mail (Email)

Mark Alder
Michael Snow
PacifiCorp/ dba Rocky Mountain Power
1407 WN Temple Ste 330
Salt Lake City, UT 84116
[e-mail]
[e-mail]

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Joe Dallas
PacifiCorp/ dba Rocky Mountain Power
825 NE Multnomah, Ste 2000
Portland, OR 97232
[e-mail]
U.S. Mail
Hand Delivered
Overnight Mail
Telecopy (Fax)
Electronic Mail (Email)
Data Request Response Center
PacifiCorp
[e-mail]
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Electronic Mail (Email)

IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.’S INITIAL COMMENTS – Page 4
CASE NO. PAC-E-22-13

Lance Kaufman, Ph.D.
Idaho Irrigation Pumpers Association, Inc.
2623 NW Bluebell Place
Corvallis, OR 97330
[e-mail]

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Thomas J. Budge
Racine Olson, PLLP
P.O. Box 1391
201 E. Center.
Pocatello, Idaho 83204-1391
[e-mail]

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Brian C. Collins
Greg Meyer
Brubaker & Associates
16690 Swingley Ridge Rd., #140
Chesterfield, MO 63017
[e-mail]
[e-mail]

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_____________________________________
ERIC L. OLSEN