IPA's Position Sample Clauses
IPA's Position. The IPA notes that the Act imposes on Ameren the ultimate responsibility to design, develop and file energy efficiency ("EE") and demand response ("DR") measures and plans with the Commission, however, Ameren shares with the DCEO the obligation to implement EE programs, while Ameren maintains exclusive control over implementing DR programs. The IPA states that Ameren is required to implement programs and measures to achieve at least 75% of the EE statutory targets, and DCEO is required to implement programs to achieve 25% of the statutory target. While DCEO is required to implement 25% of the targets, the IPA states that the costs associated with DCEO and Ameren’s EE programs are not allocated pro rata. The IPA asserts that if DCEO is unable to meet its annual energy efficiency savings goal of 25%, then Ameren and DCEO are required to jointly submit a proposal to the Commission explaining the performance shortfall, and recommending an appropriate modification to the plan. The IPA opines that the Act does not give Ameren an opportunity to request a modification of its plan from the Commission if DCEO expects to fall short of the statutorily mandated EE savings; the modification to the statutory obligation occurs only after DCEO tries, but fails to achieve the statutory obligation. The IPA avers that if Ameren fails to meet its required efficiency standards after three years, the responsibility for implementing the energy efficiency measures shall be transferred to the IPA.
IPA's Position. The IPA states that “Demand-response” is defined in Illinois as “measures that decrease peak electricity demand or shift demand from peak to off-peak periods.” 20 ILCS 3855/1-10. In its September 30, 2010 filing, the IPA notes that Ameren proposed a single DR program its refers to as a “Voltage Optimization” program, in which Ameren would install “Volt/VAR” devices to manage voltage and reactive power through its distribution and feeder systems. The IPA avers that the "Volt/VAR" devices are not actual demand reponse devices, but instead would help Ameren maintain a flatter distribution circuit profile while still delivering to customers acceptable voltage at the end of the circuit. The IPA notes that Ameren indicates this program would permit Ameren to control loads eight times per year for four hours per event, resulting in 32 hours of load reduction. However, the program is intended to be "behind the scenes" with "no detectable impact to households" and will cause no change in behavior by the customer. The IPA believes the evidence shows that if implemented, the impact should reduce annual MW load by 4.5 MW per year. The IPA asserts that most Intervenors argue against the Voltage Optimization proposal, while Staff recommended that that the Commission reject Ameren’s proposed DR program, but order Ameren to conduct a pilot of the Voltage Optimization Program to determine if the program actually works. The IPA notes that in response to this criticism, Ameren revised its proposal and removed the Voltage Optimization Program from its proposed plan and increased its energy efficiency budgets and targets accordingly. The IPA states that the net result of Ameren’s revision is that it proposes no DR program at all for the period from June 1, 2011 to May 31, 2014, and therefore Ameren’s proposed energy efficiency and demand response plan is not only deficient, but unlawful and contrary to Section 8-103(c). The IPA also opines that there is no evidence in the record that the Voltage Optimization Program is an adequate demand response program that complies with Ameren’s obligation to reduce customer demand during peak load, or to shift demand from peak to off- peak. Some parties have suggested that Ameren be given credit for this EE measure in satisfying its obligations under Section 8-103(e). ▇▇. ▇▇▇▇▇▇▇▇▇ asserts that capturing peak savings through the residential EE programs can be viewed as meeting the statute’s requirements for incremental DR resources of 0.1%...