20210823PAC to Staff 1-21-Redacted.pdf

Y ROCKY MOUNTAIN
POWER
A DNISION OF PAOFrcORP
r :: .
",
i 1_1..')L\i_.,.,-."t r LLr
:::: j iiai 13 PH 5: C9
1/+07 W North Temple, Suite 330
Saft Lake Cig, Utah 84116
August 23,2021
Jan Noriyuki
Idaho Public Utilities Commission
472W. Washington
Boise, ID 83702-5918
i an. noriyuki@puc. idaho. eov (C)
RE:ID PAC.E-21-16
IPUC Set I (l-21)
Please find enclosed Rocky Morurtain Power's Responses to IPUC ls Set Data Requests l-21.
Also provided are Attachments IPUC 8 and 9. Confidential documents will be provided upon
receipt of a signed confidentiality agreement.
If you have any questions, please feel free to call me at [phone].
Sincerely,
-lsl-J. Ted Weston
Manager, Regulation
Enclosures
PAC-E-21-16 / Rocky Mountain Power
August 23,2021
IPUC Data Request 1
IPUC Data Request 1
Please provide the source of funds for the expenses shown in Table No. 2 of the
Application.
Response to IPUC Data Request 1
The Wattsmart Battery progmm is being proposed as a Class I demand-side
management @SM) program. Therefore, if approved, expenses for this program,
including expenses shown in Table No. 2 ofthe Application, will be funded
through the Schedule 191 (Customer Services Efficiency Rate Adjustnent).
Recordholder:Shawn Grant
Sponsor:Bill Comeau
PAC-E-21-16 / Rocky Mountain Power
August 23,202I
IPUC Data Request 2
IPUC Data Request 2
What process does the Company propose for making program changes to this
proposed tarifl How frequently (i.e., annually, quarterly, as needed, etc.) does
the Company expect to consider program changes?
Response to IPUC Data Request 2
The Company proposes to manage this tariff the same way it manages its other
demand-side management (DSM) tariffs. If changes are necessary to the Schedule
114 tariff sheets, provided as Exhibit A to the Application, the Company will
submit a filing before the Idaho Public Utilities Commission (IPUC) seeking
approval. If changes are necessary to the incentive tables and other program
information provided in Exhibit B to the Application, the Company will follow
the same flexible tariff process as it currently does for other DSM programs,
which is described on page 2 of the Company's Application.
The Company intends to consider program changes on an as needed basis. The
Company frequently reviews its DSM programs and makes changes to them on a
regular basis, mainly in response to market conditions, changes in material costs,
product availability, price competition, etc., and to stay in alignment with the
Company's savings targets, budgets, and cost effectiveness requirements.
Recordholder: Michael Snow
Sponsor:Bill Comeau
PAC-E-21-16 / Rocky Mountain Power
August 23,2021
IPUC Data Request 3
IPUC Data Request 3
Please provide the projected costs for establishing the Trade Ally Network. Have
these costs been included in Table No. 2 of the Application?
Response to IPUC Data Request 3
Trade Ally costs are not included in Table No. 2 of the Application. The costs to
establish a Trade Ally Network for the Wattsmart Battery Program are expected
to be minimal with potential no cost at all. Experience from the battery demand
response program in Utah has shown that battery contactors are anxious and
willing to promote the Wattsmart Battery progftlm.
Recordholder:Shawn Grant
Sponsor:Bill Comeau
PAC-E-21-16 / Rocky Mountain Power
August 23,2021
IPUC DataRequest4
IPUC Data Roquest 4
Please provide the criteria for "axr event that is e4pected to cause syst€m outages,"
shown on page 9 of the Applicarion?
Response to IPUC lletr Request 4
An event ftsf might be erryected to cause a system outage could bs severe
foreoasted weather, planned outages, wildfires, natural disastors, etc.
Recordholder: Shavm Crrant
Sponsor:Bill Comeau
PAC-E-21-16 / Rocky Mountain Power
August 23,2021
IPUC Data Request 5
IPUC Data Request 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 work papers 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.
Confidential Response to IPUC Data Request 5
(a) Please refer to Confidential Attachment IPUC 5.
(b) Please refer to Confidential Attachment IPUC 5.
!tl"u.. refer to the confidential table provided below:
(d) The model assumed a2}-year battery measure life
Confidential information is provided subject to protection under IDAPA
31.01.01 .067 and 31.01.01.233, the Idaho Public Utilities Commission's Rules of
Procedure No. 67 - Information Exempt from Public Review, and furttrer subject
to any subsequentNon-Disclosure Agreement (NDA) executed in this proceeding.
Recordholder Shawn Grant
Program Year Avoided Costs
2022 2023 2024 2025 2026-2041
Sponsor:Bill Comeau
PAC-E-21-16 / Rocky Mountain Power
August 23,2021
IPUC Data Request 6
IPUC Data Request 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);
O) 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 ttre DBGMS. If not available, please provide the battery warranty length.
Response to IPUC Data Request 6
(a) Currently, only Sonnen batteries are eligible to participate in the Wattsmart
Battery program. Rocky Mountain Power AMP) is working with a third-party
aggregator to allow for other battery manufacturers to participate. The third-
party aggregator has established a protocol to connect batteries with
PacifiCorp's energy management system (EMS). Once proposed batteries are
connected and communicating, they will be tested to ensure batteries respond
according to program design.
(b) Please refer to the Company's response to subpart (a) above.
(c) Minimum requirements for participation are provided on RMP's website, and
can be accessed by utilizing the following website link:
hftos://www.rockymountainpower.neVsavings-energy-choices/utah-wattsmart-
battery-prog ram,/batterv -manufacturers. htm I
(d) Batteries are required to have a minimum l0-year battery life (wananty) with
a minimum of 7,500 battery cycle life.
Recordholder:Shawn Grant
Sponsor:Bill Comeau
PAC-E-21-16 / Rocky Mountain Power
August 23,2021
IPUC Data Request 7
IPUC Data Request 7
The Application states that the Wattsmart Battery program can potentially be used
for frequency reserves, contingency reserves, and regulation reseryes. Please
answer the following:
(a) How large would the program need to be, approximated by the number of
kilowaffs, to utilize it eflectively and operationally for the described purposes?
(b) Please provide a list of investnents in infrastructure, software, labor, or any
other requirements necessary and sufficient to make this feasible for the
described purposes.
Response to IPUC Data Request 7
(a) The reserve requirements for compliance with North American Electric
Reliability Corporation (NERC) standards BAL-00 I (regulation), BAL-002
(contingency) and BAL-003 (frequency) are measured in megawatts (MW).
Therefore, the minimum program size would need to be an aggregate of 1,000
kilowatts (kW) to be utilized effectively and operationally. There is currently
more than 1,000 kW of batteries enrolled in Rocky Mountain Power's AI!P)
Wattsmart Battery Program.
(b) No additional investments would be necessary to implement a Wattsmart
Battery Program in Idaho for frequency reserves, contingency reserves, and
regulation reserves.
Recordholder:Tom Burns / Shawn Grant
Sponsor:Bill Comeau
PAC-E-21-16 / Rocky Mountain Power
August 23,2021
IPUC Data Request 8
IPUC Data Request 8
In Exhibit B, the Company states the program "may be deployed when the utility
is experiencing a qualiSing event as defined by Norttrwest Power Pool." Please
provide the requirements for an event to be considered a quahfring event.
Response to IPUC Data Request 8
Please refer to Attachment IPUC 8, which provides a copy of the Northwest
Power Pool's (N\IPP) Reserve Sharing Program Documentation. Specifically,
please refer to Attachment B (Quati$ing Events).
Note: this information is publicly available and can be accessed on the NWPP
website by utilizing the following website link:
hffps://www.nwpp.org/
Recordholder:Tom Bums
Sponsor:Bill Comeau
PAC-E-21-16 / Rocky Mountain Power
August 23,2021
IPUC Data Request 9
IPUC Data Request 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 Utah, including
future applicable amendments, will be considered as forming apart of and
incorporated in said Agreement." Please provide an updated Exhibit A with
Idaho specific information for Staffs review.
Response to IPUC Data Request 9
Please refer to Attachment IPUC 9.
Recordholder:Michael Snow
Sponsor:Bill Comeau
Y ROCKY MOUNTAIN
FOWER
A DMSION OF PACIR@NP
LP.U.C. No. I Original Sheet No. 114.1
ROCKY MOUNTAIN POWER
ELECTRIC SERVICE SCHEDULE NO. 114
STATE OF IDAHO
Load Management Program
APPLICABLE: This tariff is applicable to eligible Customers who have premises located in
designated areas. Customers served by the Company in the state of Idaho taking service under the
Company's electric service schedules listed on Schedule l9l - Customer Efficiency Services Rate
Adjusfinent locatedwithinthe designated areas are eligible to participate in a Load Management Program
(Program).
PIJRPOSE: To manage electric loads through a Company-dispatched Direct Load Control
System (System).
PROGRAM DESCRIPTION: A detailed description of the Program(s) is found on the
Company website.
CUSTOMER PARTICIPATION: Participating premises are considered Program participants
for the duration of the Program(s). Customers may cancel their participation in the Program(s) at any
time. The Company or its Program contractors shall have the right to qualify progftlm participants, at
their sole discretion based on criteria the Company or Program contractors consider necessary to ensure
the effective operation of the Program(s) and utility System. Program details can be viewed on the
Company's website.
PROVISIONS OF SERYICE:
l. Qualifuing Equipment or Services, incentive amounts, and participation procedures will
be listed on the Load Management Program website.
2. lncentive delivery may vary by technology and may include cash payments and/or bill
credits.
3. Incentives may be offered year-round or for selected time periods.
4. Incentive offer availability, incentive levels, and Qualiffing Equipment or Services may
be changed to reflect changing codes and standards, sales volumes, quality assurance data,
or to enhance program cost effectiveness.5. All changes will occur with a minimum of 45 days notice and be prominently displayed
as a change on the Company's website.
ELECTRIC SERVICE REGULATIONS: Service underthis Schedule will be in accordance 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 Utilities Commission, including
futrue applicable amendments, will be considered as forming a part of and incorporated in said Agreement.
Submitted Under Case No. PAC-E-21-16
FILED: July 15,2021 EFFECTM: October 15, 2021
PAC-E-21-16 / Rocky Mountain Power
August 23,2021
IPUC Data Request 10
IPUC Data Request 10
Please provide the number of customers in the Company's Idaho service territory
that have solar installed. Please provide a breakdown of the number of customers
by electric service schedule that are listed on Schedule 191.
Response to IPUC Data Request 10
As of June 30,2021, Rocky Mountain Power (RNP) hadl,470 customers with
installed solar systems. A break down by service schedules listed on Schedule 191
is provided in the table below:
Schedule Customer
Count
Schedule I 1.160
Schedule 6 6
Schedule 6A I
Schedule 7 0
Schedule 7A 0
Schedule 9 0
Schedule 10 0
Schedule ll 0
Schedule 12 0
Schedule 19 0
Schedule 23 45
Schedule 23A 0
Schedule 24 0
Schedule 35 0
Schedule 35A 0
Schedule 36 258
Total 1,470
Recordholder: Tony Worthington \ Honorino Lora Jr
Sponsor: Bill Comeau
PAC-E-21-16 / Rocky Mountain Power
August 23,2021
IPUC Data Request I I
IPUC Data Request 11
Please provide the number of customers in the Company's Idaho service tenitory
that completed a solar installation for 2019 and2020. Please provide a
breakdown ofthe number of customers by electric service schedule that are listed
on Schedule 191.
Response to IPUC Data Request 11
Rocky Mountain Power (RNP) had74l customers complete installation of a solar
system in 2019 and2020. A break down by service schedules listed on Schedule
191 is provided in the table below:
Schedule Customer
Count
Schedule I s90
Schedule 6 4
Schedule 6A I
Schedule 7 0
Schedule 7A 0
Schedule 9 0
Schedule 10 0
Schedule ll 0
Schedule 12 0
Schedule 19 0
Schedule 23 t7
Schedule 23A 0
Schedule 24 0
Schedule 35 0
Schedule 35A 0
Schedule 36 129
Total 741
Recordholder: Tony Worthington \ Honorino Lora Jr
Sponsor: Bill Comeau
PAC-E-21-16 / Rocky Mountain Power
August 23,2021
IPUC Data Request 12
IPUC Data Request 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 tade-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)
Response to IPUC Data Request 12
As the program is intoduced to ldaho customers, the "lease" option will not be
available. Details on a "lease" option are still being considered and developed.
Once a "lease" option is more developed the details will be shared with Idaho
stakeholders prior to being offered.
Recordholder:Shawn Grant
Sponsor:Bill Comeau
PAC-E-21-16 / Rocky Mountain Power
August 23,2021
IPUC Data Request 13
IPUC Data Request 13
Page 3 of the Application states "[i]nitially, batteries will be used to oflset
customers' load". Who is proposed to have contol over dispatch decisions when
batteries are used to of[set customers' load? Please explain.
Response to IPUC Data Request 13
Rocky Mountain Power AI\4P) / PacifiCorp will have contol over the dispakh
decisions for when batteries are used to offset customer load based on current and
future grid needs.
Recordholder:Shawn Grant
Sponsor:Bill Comeau
PAC-E-21-16 / Rocky Mountain Power
August 23,2021
IPUC Data Request 14
IPUC Data Request 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 2021 will be the maximum amount of
$15O/kilowatt (kVO multiplied by the commitrnent term. The offered incentive for
customers with solar installed after August202l will be set at $100/kW multiplied
by the commitnent 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 August202l;
(c) Will this incentive structure apply to commercial customers now or in the
future? Please explain why or why not;
(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.
Response to IPUC Data Request 14
(a) The term "installed" in this context is referring to the installation of solar
generation and not the installation of a battery. If a customer has installed solar
generation prior to September 1,2021, they will be eligible to receive the $150
per kilowatt ($ltW) incentive. If a customer has installed solar generation on or
after September l, 2021, they will be eligible for the $100/kW incentive.
(b) It will be more challenging to get customers with existing solar to participate in
the program than customers without existing solar, thus requiring a lower
incentive for customers who install solar on or after September 1,2021. If the
Wattsmart Battery progftrm is approved, Trade Allies will market both solar
and batteries as an attractive package to customers. However, customers with
existing solar will have to purchase a battery separately, which is not as
desirable as a packaged deal. Additionally, customers with existing solar are
already generating excess energy on the grid. Offering a higher incentive to
obtain participation from customers with existing solar will enable the
Company to utilize the excess solar already being generated.
PAC-E-21-16 / Rocky Mountain Power
August 23,2021
IPUC Data Request 14
(c) The incentive sfructure will be immediately available to commercial customers
if they install qualified eligible batteries.
(d) At this time, participation incentives are intended to only be available for
batteries charged by solar power. If wind power battery technology is a proven
technology, it may be considered for future inclusion within the Wattsmart
Battery program.
(e) Participation incentives are based on continuous output (kW) of the battery
which is available to Rocky Mountain Power (RMP). Incentive will not be
based on nameplate solar generation capacity.
Recordholder: Shawn Grant
Sponsor: Bill Comeau
PAC-E-21-16 / Rocky Mountain Power
August 23,2021
IPUC DataRequest 15
IPUC Data Request 15
Do Table No. 2 @stimated 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 gnd
management? Please explain.
Response to IPUC Data Request 15
Estimates provided in Table No. 2 and Table No. 3 in the Application assume
batteries may be used for all grid management applications.
Recordholder:Shawn Grant
Sponsor:Bill Comeau
PAC-E-21-16 / Rocky Mountain Power
August 23,2021
IPUCDataRequest 16
IPUC Data Rcquest 16
Please confirm whether Table No. 1 in the Application shows incentives for using
batteries only to offseJ customerso load. Will new incentives be developed when
batteries are used for other utility purposes? Ploase e4plain.
Response to IPUC Deta Request 16
Table No. I in the Application (Wattsmart Battery Inccntives) assumes batteries
may be used for all gnd services.
Recordholdq: Shawn Grant
Sponsor:Bill Comeau
PAC-E-21-16 / Rocky Mountain Power
August 23,2021
IPUC DataRequest 17
IPUC Data Request 17
Please explain the impact of this program on the Company's ability to recover its
fixed costs due to currenfly collecting those costs through volumetric rates and
explain how the Company will address this issue.
Response to IPUC Data Request 17
Please refer to the Company's response to IPUC Data Request l. The Company
will recover the costs specifically associated with the Wattsmart Battery progftrm
through Schedule l9l (Customer Effrciency Services Rate Adjustnent).
ln terms of broader recovery of overall utility fixed costs, the Company does not
anticipate that battery adoption itself will lower volumetic sales and reduce fixed
cost recovery. Customer-sited batteries rather change the timing of energy
consumption and can increase volumetic energy sales as efficiency losses are
experienced.
Recordholder: Shawn Grant
Sponsor:Bill Comeau
PAC-E-21-16 / Rocky Mountain Power
August 23,2021
IPUC Data Request 18
IPUC Data Request 18
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) V/hy does the analysis utilize the ten-year benefit estimates developed for the
Utah Cool Keeper Program, which is a Utah program?
(b) Please provide work papers that illustrate "[e]ach year after ttre initial forecast
utilized the year 10 assumption to calculate annual benefits."
Response to IPUC Data Request 18
(a) The analysis utilizes a "methodology" developed to calculate cost
effectiveness for Rocky Mountain Power's (RMP) Utah Cool Keeper demand
response program. This same "methodology" was used to calculate cost
eflectiveness for the proposed Wattsmart Battery program. The proposed
progftrm in Idaho has unique savings, costs, program benefits, etc.
(b) Please refer to the Company's response to IPUC Data Request 5, specifically
Confidential Attachment IPUC 5.
Recordholder:Shawn Grant
Sponsor:Bill Comeau
PAC-E-21-16 / Rocky Mountain Power
August 23,2021
IPUC Data Request 19
IPUC Data Request 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
extapolatedto204l, the numberwill be significantly less. Please explainwhy
the anticipated amount in Exhibit C does not align with the extrapolated tend.
Response to IPUC Data Request 19
The participation numbers in the second column of Table No. 3 in the Application
are estimated participation numbers each year and are not cumulative. Estimated
program participation during 2022 throtgh2027 is estimated to be 1,950
batteries. The Company's model estimates an additional475 batteries will be
added to the progftrm each year from 2028 through 2041. This would equate to
6,650 batteries from 2028 through 2A41.
Recordholder:Shawn Grant
Sponsor:Bill Comeau
PAC-E-21-16 / Rocky Mountain Power
August 23,2021
IPUC Data Request 20
IPUC Data Request 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 l:1. Please explain whether it is a reasonable ratio in the
industry, given the fact that many battery projects use 1:4 or l:2 ratios in the
industry.
Response to IPUC Data Request 20
The difference between total site kilowatt (kW) and total generator kW is line
loss. The values at generation include line losses between the customer site and
the generation source. The analysis in Confidential Exhibit C has factored in what
is cunently known about the battery technology and capacity being used for the
proposed Wattsmart Battery progftrm. As technology advances and more data is
gathered over time, the evaluation of battery capacity and other meffics will
evolve.
Recordholder: Shawn Grant
Sponsor:Bill Comeau
PAC-E-21-16 / Rocky Mountain Power
August 23,2021
IPUC Data Request 21
IPUC Data Request 21
Table No. 2 of the Application shows that Softrryare Costs for 2022,2023, and
2024 are $5,000, $15,000, and $31,000, respectively. Table No. 2 in Exhibit C
shows that Softrvare Costs for 2022,2023, and2024 are $5,200, $15,600, and
$31,200, respectively. Please reconcile the differences.
Response to IPUC Data Request 21
The costs in Table No. 2 from Confidential Exhibit C were used to calculate the
estimated cost effectiveness, meaning that based on the cost effectiveness results,
it is assumed the program would be cost effective if these costs came to fruition.
ln Table No. 2 of the Application, it was forecasted that softrvare costs would
come in slightly under the assumptions used in the cost effectiveness analysis.
Recordholder:Shawn Grant
Sponsor:Bill Comeau