20210819Staff 22-35 to PAC.pdf

ERICK SHANER
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
(208) 334-03r4
IDAHO BAR NO. 5214
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Street Address for Express Mail:
1 I33I W CHINDEN BLVD, BLDG 8, SUITE 2OI-A
BOISE, ID 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.-21-16
SECOND PRODUCTION
REQUEST OF THE
COMMISSION STAFF
TO ROCKY MOUNTAIN
POWER
The Staff of the Idaho Public Utilities Commission, by and through its attorney of record,
Erick Shaner, Deputy Attomey General, requests that Rocky Mountain Power provide the
following documents and information as soon as possible, but no later than THURSDAY,
SEPTEMBER 9, 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 identi$ the name, job title, location, and telephone
number of the record holder.
SECOND PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER
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I AUGUST I9,2O2I
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.22: Please explain how the Company will coordinate the Battery
Demand Response Program with the Company's Net Metering Program.
REQUEST NO. 23: Will the Net Metering Program need to be modified to
accommodate the Battery Demand Response Program? Please explain which aspects of the Net
Metering program (e.g., development of an export valuation of energy, how the company will
recover its costs, etc.) will need to be modified to accommodate the initial load reduction phase
as well as future phases?
REQUEST NO.24: Please explain how the different tests in Table 4 in the Application
will be utilized in the Company's Integrated Resource Plan (IRP). Please explain how the
amount of Battery Demand Response Program resources will be selected into portfolios.
REQUEST NO. 25: Has the Company implemented Battery Demand Response
Programs in other states that use batteries for other functions beyond load reduction, such as
frequency reserve, contingency reserve, regulation reserves, regional grid management, backup
power and other ancillary benefits? Please explain.
REQUEST NO.26: Please provide an implementation roadmap of the different phases
of functionality that will or could be implemented throughout the lifecycle of this program as
described in the Application. Please include the dependencies that need to be in place to
implement each phase including but not limited to:
a. Regulatory frameworks that need to be developed;
b. Participation rates and customer acceptance;
c. Improvements in battery storage infrastructure performance and/or costs;
d. lnfrastructure that needs to be installed by the customer or by the Company; and
e. Removal of any roadblocks not included above.
SECOND PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 2 AUGUST I9,2O2I
REQUEST NO.27: Please provide diagrams that illustrate the different components at
both the participant's site and components that the Company needs to install for the battery
demand response program to be implemented. Please include:
a. A description of the functionality of each component and the relationship/linkage
between components by illustrating and describing the inputs and outputs of each
component;
b. If different, please provide separate a diagram for both residential and commercial
participants; and
c. If the different phases provided in the roadmap requested above require different
or additional components, please provide a separate diagram for each phase.
REQUEST NO. 28: Please describe the mitigation measures that the Company will
perform or implement to minimize andlor eliminate the risk of potential future grandfathering of
program rates, incentives, or other aspects of the program for legacy participants, if the program
or aspects of the program need to be discontinued or changed in the future.
REQUEST NO.29: Please identifu and describe aspects or functionality of the program
that provide benefits to the entire system versus those that only benefit the Idaho jurisdiction.
Please provide a quantification and a breakdown of those benefits by the system and for ldaho,
and the basis used to determine the amounts.
REQUEST NO.30: Does the program allow installation of batteries only, without
paired generators, in the initial load reduction phase and future phases? If it is allowed in the
initial phase, does the proposed incentives apply to batteries without paired generators? Please
explain.
REQUEST NO.31: Please answer the following regarding incentive payments:
a. Will the Company set a maximum total budget for incentive payments to
participants for the program? Please explain.
b. Will there be a maximum cap on the incentive dollars a participant can receive?
SECOND PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER J AUGUST I9,2O2I
c. If there is a maximum total budget and no cap for the amount of dollars a
participant can receive, how will the Company ensure that participants with large
battery systems do not consume a disproportionate share of the incentive budget
so that incentives are available to a greater number of participants?
REQUEST NO.32: How long does the Company anticipate the proposed incentives in
the current form will last until they are changed?
REQUEST NO. 33: Table 3 in the Application provides an estimated participation trend
for the next six years. Please provide a breakdown of new batteries versus existing batteries in
the trend.
REQUEST NO.34: When the Company modifies the program (e.g., incentive
payments, commitment terms, etc.) in the future, please explain how the Company will manage
the transition for existing participants and/or customers preparing to participate.
REQUEST NO.35: Please provide copies of all the Company's marketing materials
and advertisements for battery storage programs in the Company's other jurisdictions.
,nd
DATED at Boise, Idaho, this / / auvof August 2021.
Erick Shaner
Deputy Attorney General
i:umisc:prodreq/pace2l. I 6esbl prod req 2
SECOND PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 4 AUGUST I9,2O2L
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 19th DAY OF AUGUST 2021, SERVED
THE FOREGOING SECOND PRODUCTION REQUEST OF THE COMMISSION
srAFF TO ROCKY MOUNTATN POWER, IN CASE NO. PAC-E-21-16, BY E-MAILING
A COPY THEREOF, TO THE FOLLOMNG:
TED WESTON
MICHAEL SNOW
ROCKY MOUNTAIN POWER
I4O7 WEST NORTH TEMPLE STE 330
SALT LAKE CITY UT 84I 16
E-MAIL : ted.weston@oacifi corp.com
michael. snow@f acifi com.com
DATA REQUEST RESPONSE CENTER
E.MAIL OIILY:
datareq uest@pac i fi c orp.c om
EMILY WEGENER
ROCKY MOI.INTAIN POWER
1407 WN TEMPLE STE 320
SALT LAKE CITY UT 84116
E-MAIL: [e-mail]
Y
CERTIFICATE OF SERVICE