20210909PAC to Staff 22-35.pdf

1407 W North Temple, Suite 330 Salt Lake City, Utah 84116
September 9, 2021
Jan Noriyuki Idaho Public Utilities Commission 472 W. Washington
Boise, ID 83702-5918 [e-mail] (C)
RE: ID PAC-E-21-16
IPUC Set 2 (22-35)
Please find enclosed Rocky Mountain Power’s Responses to IPUC 2nd Set Data Requests 22-35. Also provided is Attachment IPUC 27.
If you have any questions, please feel free to call me at [phone].
Sincerely,
____/s/____ J.Ted WestonManager, Regulation
Enclosures
RECEIVED
2021 SEP 9 PM 5:03
IDAHO PUBLIC
UTILITIES COMMISSION
PAC-E-21-16 / Rocky Mountain Power September 9, 2021 IPUC Data Request 22
IPUC Data Request 22 Please explain how the Company will coordinate the Battery Demand Response Program with the Company's Net Metering Program.
Response to IPUC Data Request 22 Customers who participate in the proposed Wattsmart Battery program will initially be required to be enrolled in the Company’s Net Metering Program.

Recordholder: Shawn Grant Sponsor: Bill Comeau

PAC-E-21-16 / Rocky Mountain Power September 9, 2021 IPUC Data Request 23
IPUC Data Request 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?
Response to IPUC Data Request 23
The Company is not aware of any changes that would need to be made to the Net Metering Program at this point, that could change depending on the outcome of its pending Net Metering application, Case No. PAC-E-19-08.
As noted in the direct testimony of Ms. Joelle R. Steward in Case No. PAC-E-19-
08, approximately 89 percent of the Company’s fixed costs for residential customers are recovered through volumetric kilowatt-hour usage. The Battery Program could increase the cost shifting caused by this rate design to non-net
metering customers without the proper rate design and value for exported energy.
The Company will continue to monitor both programs and their interplay with each other to determine if future modifications are needed.

Recordholder: Shawn Grant Sponsor: Bill Comeau

PAC-E-21-16 / Rocky Mountain Power September 9, 2021 IPUC Data Request 24
IPUC Data Request 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.
Response to IPUC Data Request 24
The Integrated Resource Plan (IRP) characterizes costs for demand response
based on the primary cost-effectiveness test used in each jurisdiction. Battery costs are characterized from the perspective of the Total Resource Cost (TRC) test for the Battery Demand Response programs for selection in the 2021 IRP for all Pacific Power jurisdictions. Rocky Mountain Power jurisdictions rely on the application of the Utility Cost Test (UCT) for cost characterization in the 2021
IRP.1 The 2021 IRP seeks to optimize system resources to serve anticipated
future load. Using optimization, the model does not provide a numeric benefit-cost ratio for each resource; rather it provides a pass/fail determination as to whether a given resource will be selected as the least cost least risk resource to
meet resource needs within the model.
Recordholder: Dan Swan / Peter Schaffer Sponsor: Bill Comeau

1 See Chapter 2 of PacifiCorp’s Conservation Potential Assessment for 2021-2040 for more detail on cost characterization and cost-effectiveness tests. Available online: https://www.pacificorp.com/content/dam/pcorp/documents/en/pacificorp/energy/integrated-resource-plan/2021-irp/2021-irp-support-and-studies/cpa-final-report-and-appendices/PacifiCorp%20DSM%20Potential%20Report%20-%20Vol%201%20-%20FINAL_2-26-2021.pdf
PAC-E-21-16 / Rocky Mountain Power September 9, 2021 IPUC Data Request 25
IPUC Data Request 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. Response to IPUC Data Request 25

Yes, the Wattsmart Battery Program in Utah is fully functional and can provide various grid management solutions as outlined in this data request. The Company has developed a Distributed Battery Grid Management Solution (DBGMS) which provides real-time visibility and dispatch capabilities to utilize enrolled program batteries for flexible grid conditions.

Recordholder: Shawn Grant
Sponsor: Bill Comeau

PAC-E-21-16 / Rocky Mountain Power September 9, 2021 IPUC Data Request 26
IPUC Data Request 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) Infrastructure that needs to be installed by the customer or by the Company;
and
(e) Removal of any roadblocks not included above.
Response to IPUC Data Request 26
(a) The only regulatory framework needed to perform the full functionality of the program as currently proposed is approval of the Company’s Application and new Electric Service Schedule No. 114 – Load Management Program.

(b) Estimated participation rates for 2022 through 2027 are outlined in Table 3 of the Company’s Application. Based on the Company’s Wattsmart Battery program in Utah, the market is ready for this program with high
interest from customers. The Company expects the same response in
Idaho. (c) For select batteries, the current technology is sufficient to meet the energy needs for advanced demand response. Battery storage technology is still relatively new and continuous innovation is expected to occur in the short-
and long-term. The Company expects costs to decrease and options for
additional batteries to become available in the next 1 to 3 years. (d) Under the current design of the Wattsmart Battery Program, no additional infrastructure is required for the Company or customer to participate and benefit from the program beyond existing and new battery installations. (e) With new technology and innovative programs, such as the Company’s proposed Wattsmart Battery program, there may be unforeseen barriers and roadblocks over time. The Company will address those barriers when
identified and will work with Idaho stakeholders as appropriate to resolve.
PAC-E-21-16 / Rocky Mountain Power September 9, 2021 IPUC Data Request 26
The current battery technology available within the proposed Wattsmart Battery Program for Idaho currently has full functionality for demand Response. The Company expects the full functionality to be implemented in Idaho within 0 to 12
months after program approval.
Recordholder: Shawn Grant

Sponsor: Bill Comeau
PAC-E-21-16 / Rocky Mountain Power September 9, 2021 IPUC Data Request 27
IPUC Data Request 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;
If different, please provide separate a diagram for both residential and commercial participants; and (b) If the different phases provided in the roadmap requested above require
different or additional components, please provide a separate diagram for each
phase. Response to IPUC Data Request 27

Customers that choose to participate in the Wattsmart Battery program will only
need a reliable Wi-Fi/internet connection. The batteries are controlled through
internet communication. There are no special or additional components needed for participants or the Company to install for the battery demand response program to be implemented. Batteries currently being installed in the Company’s Idaho service territory have
the same installation requirements regardless if they enroll in the proposed
Wattsmart Battery program.
Please refer to Attachment IPUC 27 which provides a one-line diagram of the approved battery installation process. Recordholder: Shawn Grant

Sponsor: Bill Comeau
PAC-E-21-16 / Rocky Mountain Power September 9, 2021 IPUC Data Request 28
IPUC Data Request 28 Please describe the mitigation measures that the Company will perform or implement to minimize and/or 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.
Response to IPUC Data Request 28

The Company has made it clear through vendor training, program website, terms
and conditions, tariff sheets, flexible tariff tables, etc. that incentives are subject to change at any time and are not guaranteed, similar to the Company’s other demand-side management (DSM) programs. Program participants will receive an upfront enrollment incentive for a four-year commitment to the program. After the initial payment, there is no perpetually guaranteed annual participation incentive. Program incentives are expected to change as the program matures. All incentive changes will be communicated to customers and will occur with a minimum 45 days’ notice prominently displayed as a change on the Company’s website.

Recordholder: Shawn Grant Sponsor: Bill Comeau
PAC-E-21-16 / Rocky Mountain Power September 9, 2021 IPUC Data Request 29
IPUC Data Request 29 Please identify 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 Idaho, and the basis used to determine the amounts. Response to IPUC Data Request 29

As noted in the Company’s application, the Wattsmart Battery Program will promote and incentivize the installation of individual batteries for system-wide integration which will facilitate the Company’s grid management and load shaping. Like all demand-side management programs the Battery Program will also reduce customers’ energy use and demand in Idaho which in turn reduces cost allocation
to the state.
Recordholder: Shawn Grant
Sponsor: Bill Comeau

PAC-E-21-16 / Rocky Mountain Power September 9, 2021 IPUC Data Request 30
IPUC Data Request 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. Response to IPUC Data Request 30

In the initial phase of the program, only batteries paired with solar generation will be eligible for enrollment incentives in the Wattsmart Battery Program. The Company may consider enrolling batteries without paired solar in future phases.
Recordholder: Shawn Grant
Sponsor: Bill Comeau
PAC-E-21-16 / Rocky Mountain Power September 9, 2021 IPUC Data Request 31
IPUC Data Request 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?
(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?
Response to IPUC Data Request 31 (a) The Company will develop and manage an annual estimated budget as it
does with its other demand-side management (DSM) programs to
prudently manage the portfolio. (b) In the proposed program, only batteries up to 8 kilowatts (kW) are eligible to participate. Customers who install eligible batteries will receive the currently offered incentive amount. Experience from the Utah Wattsmart
Battery program indicates customers are not installing multiple batteries in
an attempt to receive additional incentives. Larger residential and commercial batteries are currently not approved for the program, so incentive payments to participants are predictable with no customers
receiving inordinate incentive levels from large battery installations. As
batteries evolve and more batteries become eligible for the program, the Company may establish maximum incentive caps per customer to manage the budget and diversify participation. (c) Please refer to the Company’s response to subpart (b) above. The Company
intends to have the program available to all customers with qualifying battery
systems while managing the program within a budget, as it does with its other DSM programs. The Company will evaluate participation and budgets on a periodic basis to confirm the program is functioning as intended. If participation is exceeding forecasts and is expected to exceed program budgets, incentives and other metrics will be adjusted accordingly to maintain a year-round offering. Stopping the program mid-year due to budget issues would create disruption to the Company, customers, and the local battery contractors.

PAC-E-21-16 / Rocky Mountain Power September 9, 2021 IPUC Data Request 31
Recordholder: Shawn Grant Sponsor: Bill Comeau
PAC-E-21-16 / Rocky Mountain Power September 9, 2021 IPUC Data Request 32
IPUC Data Request 32 How long does the Company anticipate the proposed incentives in the current form will last until they are changed?
Response to IPUC Data Request 32 Proposed incentives will be modified based on overall participation and budget availability. Incentive adjustments may occur within the first 12 months if program participation estimates are exceeded.

Recordholder: Shawn Grant Sponsor: Bill Comeau

PAC-E-21-16 / Rocky Mountain Power September 9, 2021 IPUC Data Request 33
IPUC Data Request 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.
Response to IPUC Data Request 33
The Company is estimating 95+ percent of all batteries that participate in the
Wattsmart Battery Program will be new battery installations. Recordholder: Shawn Grant
Sponsor: Bill Comeau

PAC-E-21-16 / Rocky Mountain Power September 9, 2021 IPUC Data Request 34
IPUC Data Request 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.
Response to IPUC Data Request 34
In addition to posting a prominently displayed 45-day notice on the Company’s website, existing customers will be notified through electronic communication
when incentive modifications will become effective so they can plan accordingly.
Incentive adjustments for the Company’s other demand-side management (DSM) programs are managed in a similar fashion. Recordholder: Shawn Grant

Sponsor: Bill Comeau
PAC-E-21-16 / Rocky Mountain Power September 9, 2021 IPUC Data Request 35
IPUC Data Request 35 Please provide copies of all the Company's marketing materials and advertisements for battery storage programs in the Company's other jurisdictions.
Response to IPUC Data Request 35 The Company has exclusively marketed the program through local battery installers and the Company’s program website:
www.rockymountainpower.net/battery.
Recordholder: Shawn Grant Sponsor: Bill Comeau