20210802Staff 1-21 to PAC.pdf

ERICK SHANER
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83]20-0074
[phone]
IDAHO BAR NO. 5214
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Street Address for Express Mail:
I I331 W CHINDEN BLVD, BLDG 8, SUITE 2OI-A
BOISE, TD 83714
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION OF
ROCKY MOUNTAIN POWER FOR
AUTHORITY TO IMPLEMENT A BATTERY
DEMAND RESPONSE PROGRAM
CASE NO. PAC-E-21-I6
FIRST PRODUCTION
REQUEST OF THE
COMMISSION STAFF
TO ROCKY MOUNTAIN
POWER
The Staff of the tdaho Public Utilities Commission, by and through its attomey of record,
Erick Shaner, Deputy Attorney General, requests that Rocky Mountain Power provide the
following documents and information as soon as possible, but no later than MONDAY,
AUGUST 23,2021.
This Production Request is to be considered as continuing, and Rocky Mountain Power is
requested to provide, by way of supplementary responses, additional documents that it, or any
person acting on its behall may later obtain that will augment the documents or information
produced.
Please provide answers to each question, supporting workpapers that provide detail or are
the source of information used in calculations, and the name, job title, and telephone number of
the person preparing the documents. Please identiS the name, job title, location, and telephone
number of the record holder.
FIRST PRODUCTION REQUEST
TO ROCKY MOLINTAIN POWER
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1 AUGUST 2,2021
In addition to the written copies provided as response to the requests, please provide all
Excel spreadsheets and electronic files on CD with formulas intact and enabled.
REQUEST NO. l: Please provide the source of funds for the expenses shown in Table
No. 2 of the Application.
REQUEST NO.2: What process does the Company propose for making program
changes to this proposed tariff? How frequently (i.e., annually, quarterly, as needed, etc.) does
the Company expect to consider program changes?
REQUEST NO.3: Please provide the projected costs for establishing the Trade Ally
Network. Have these costs been included in Table No. 2 of the Application?
REQUEST NO. 4: Please provide the criteria for "an event that is expected to cause
system outages," shown on page 9 of the Application?
REQUEST NO. 5: For the Company's cost-effectiveness calculation provided in
Exhibit C, please provide the following in Excel format with all formulas enabled:
a. Please provide all workpapers for the cost effectiveness study shown in Exhibit C.
Please include all modeled assumptions;
b. Please provide the Company's benefits calculation for each year for the entire
analysis period. Please provide the benefits calculations from the Utility Cost
Test ("UCT) perspective;
c. Please provide the avoided cost used for the Company's benefits calculations; and
d. Please provide the modeled estimated battery life for the Company's analysis.
REQUEST NO. 6: For batteries, please provide the following:
a. A list of battery-storage equipment and equipment manufacturers that are capable
of communicating with the Company's Distributed Battery Grid Management
Solution ("DBGMS");
FIRST PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 2 AUGUST 2,2021
b. A list of battery-storage equipment and equipment manufacturers that meet the
requirements for utility-controlled demand response;
c. The requirements for a battery-storage system to be integrated into DBGMS; and
d. The average life for each battery that is currently available to be integrated into
the DBGMS. If not available, please provide the battery warranty length.
REQUEST NO. 7: The Application states that the Wattsmart Battery program can
potentially be used for frequency reserves, contingency reserves, and regulation reserves. Please
answer the following:
a. How large would the program need to be, approximated by the number of
kilowatts, to utilize it eflectively and operationally for the described purposes?
b. Please provide a list of investments in infrastructure, software, labor, or any other
requirements necessary and sufficient to make this feasible for the described
purposes.
REQUEST NO. 8: In Exhibit B, the Company states the program "may be deployed
when the utility is experiencing a qualiffing event as defined by Northwest Power Pool." Please
provide the requirements for an event to be considered a qualifuing event.
REQUEST NO. 9: Exhibit A, states "The Electric Service Regulations of the Company
on file with and approved by the Public Service Commission of the State of Utaft, including
future applicable amendments, will be considered as forming a part of and incorporated in said
Agreement." Please provide an updated Exhibit A with Idaho specific information for Staff s
revlew
- REQUEST NO. l0: Please provide the number of customers in the Company's Idaho
service temitory that have solar installed. Please provide a breakdown of the number of
customers by electric service schedule that are listed on Schedule l9l .
FIRST PRODUCTION REQUEST
TO ROCKY MOTINTAIN POWER aJ AUGUST 2,2021
REQUEST NO. 11: Please provide the number of customers in the Company's Idaho
service territory that completed a solar installation for 2019 and2020. Please provide a
breakdown of the number of customers by electric service schedule that are listed on Schedule
191.
REQUEST NO. 12: On page 7 of the Application, the Company states "the Company
may provide a lease type agreement option, where the Company will work with qualified trade-
allies to install and maintain the batteries." Please provide additional details around the "lease
type agreement option" by answering the following:
a. How does the Company plan to fund this option?
b. What is the length of the proposed lease options?
c. Will customers still receive other incentives?
d. Who are the qualified trade-allies and what services will the trade-allies provide?
e. What are the requirements to qualiff for a "lease type agreement"? (e.g., kW size
or residential services with solar only)
REQUEST NO. 13: Page 3 of the Application states "[i]nitially, batteries will be used
to off-set customers' load". Who is proposed to have control over dispatch decisions when
batteries are used to offset customers' load? Please explain.
REQUEST NO. 14: Page 5 of the Application states "[i]ntially, residential incentives
will be split between customers with and without existing solar. The incentive for customers
with solar installed prior to September 2021wlll be the maximum amount of $15O/kilowatt
("kW") multiplied by the commitment term. The offered incentive for customers with solar
installed after August202l will be set at $100/kW multiplied by the commitment term." Please
answer the following questions:
a. Please confirm "installed" above refers to the installation of a solar generator, not
the installation of a battery;
b. Please explain why the incentive is reduced after August212l;
c. Will this incentive structure apply to commercial customers now or in the future?
Please explain why or why not;
FIRST PRODUCTION REQUEST
TO ROCKY MOLINTAIN POWER 4 AUGUST 2,2021
d. Please confirm that the incentives apply to solar-powered batteries only and that
batteries powered by other resources such as wind do not qualifu for these
incentives. If so, please explain why the incentives are available for solar-
powered batteries only; and
e. Please confirm that the enrollment incentive and the participation incentive are
applied to the nameplate capacity of a battery, not the nameplate of a solar
generator.
REQUEST NO. 15: Do Table No. 2 (Estimated Program Costs by Category) and Table
No. 3 (Estimated 6-Year Program Participation) assume that batteries are used to offset
customers' load only, without providing any other capabilities, such as grid management?
Please explain.
REQUEST NO. 16: Please confirm whether Table No. I in the Application shows
incentives for using batteries only to offset customers' load. Will new incentives be developed
when batteries are used for other utility purposes? Please explain.
REQUEST NO. 17: Please explain the impact of this program on the Company's ability
to recover its fixed costs due to currently collecting those costs through volumetric rates and
explain how the Company will address this issue.
REQUEST NO. l8: Exhibit C includes the cost-effectiveness findings for Guidehouse's
analysis of the proposed Battery Demand Resource Program in Idaho. Please answer the
following questions.
a. Why does the analysis utilize the ten-year benefit estimates developed for the
Utah Cool Keeper Program, which is a Utah program?
b. Please provide workpapers that illustrate "fe]ach year after the initial forecast
utilized the year 10 assumption to calculate annual benefits."
FIRST PRODUCTION REQUEST
TO ROCKY MOLTNTAIN POWER 5 AUGUST 2,2021
REQUEST NO. 19: Exhibit C states that the program is projected to include 8,600
batteries at the end of 2041. However, if the trend in Table No. 3 in the Application is linearly
extrapolatedto 2041, the number will be significantly less. Please explain why the anticipated
amount in Exhibit C does not align with the extrapolated trend.
REQUEST NO. 20: Table No. 2 and Table No. 3 in Exhibit C show that the ratio
between Total Site kW, which is the battery capacity, and Total Generator kW, which is the
generator capacity, is close to 1: l. Please explain whether it is a reasonable ratio in the industry,
given the fact that many battery projects use l:4 or l:2 ratios in the industry.
REQUEST NO. 21: Table No. 2 of the Application shows that Software Costs for2022,
2023, and2024 are $5,000, $15,000, and $31,000, respectively. Table No. 2 in Exhibit C shows
that Software Costs for 2022,2023, and2024 are $5,200, $15,600, and $31,200, respectively.
Please reconcile the differences.
DATED at Boise, Idaho, tni, ZP aay of Augu st202l.
Erick Shaner
Deputy Attorney General
i:umisc:prodreq/pace2l. l6esbl prod req I
FIRST PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 6 AUGUST 2,2021
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 2Nd DAY OF AUGUST 2021, SERVED
THE FOREGOING FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF
TO ROCKY MOUNTAIN POWER, N CASE NO. PAC-E-21-16, BY E-MAILING A
COPY THEREOF, TO THE FOLLOWING:
TED WESTON
MICHAEL SNOW
ROCKY MOLINTAIN POWER
1407 WEST NORTH TEMPLE STE 330
SALT LAKE CITY UT 84I16
E-MAIL : ted.weston@pacifi corp.com
michael. snow@pacifi corp. com
DATA REQUEST RESPONSE CENTER
E-MAIL ONLY:
datareq uest@pacifi corp.com
EMILY WEGENER
ROCKY MOUNTAIN POWER
I4O7 WN TEMPLE STE 320
SALT LAKE CITY UT 84116
E-MAIL: [e-mail]
CERTIFICATE OF SERVICE