20210922Staff 36-50 to PAC-Redacted.pdf

ERICK SHANER
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-007 4
[phone]
IDAHO BAR NO. 5214
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Street Address for Express Mail:
1I33I 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.-2I.I6
REDACTED THIRI)
PRODUCTION REQUEST OF
THE COMMISSION STAFF
TO ROCKY MOTJNTAIN
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 WEDNESDAY,
ocroBER 13,2021.
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 behalf, 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 identifu the name, job title, location, and telephone
number of the record holder.
REDACTED THIRD PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 1
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SEPTEMBER2Z,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. 36: In the Company's Wattsmart Battery program in Utah, the
Company's website states, "bafferies will not be controlled daily from November through
February." Is this the Company's intent for the Wattsmart Battery program in Idaho as well?
Please explain.
REQUEST NO.37: The Company's cost-effectiveness calculation is modeled using a
2}-year measure life; however, the batteries are required to have a minimum of a l0-year life.
Please explain the reasoning for modeling the baffery measure life for 20-years. In the response,
please provide supporting documents, workpapers, and/or research that supports a 2O-year
battery measure life. Please also indicate the battery type being modeled.
REQUEST NO.38: The Company's response to Production Request No. 26 (c) states
"for select bafferies, the current technology is sufficient to meet the energy needs for advanced
demand response." Please explain advanced demand response. How does advanced demand
response differ from traditional demand response?
REQUEST NO. 39: In the website link provided to Staffin the Company's response to
Production Request No. 6 (c), the Company's website states, "for batteries to be eligible for our
program, they must meet the following requirements: ability to integrate with Rocky Mountain
Power's Distributed Battery Grid Management System (DBGMS)." What are the requirements
from the battery manufacturers to integrate their batteries into the Company's DBGMS?
REQUEST NO. 40: Regarding the Company's response to Production RequestNo. 4,
please describe the Company's process for determining whether events warrant minimizing
Wattsmart Battery dispatch events. Please also describe any communication the Company
would have with its customers in the Wattsmart Battery progftlm during these events that are
expected to cause system outages.
REDACTED THIRD PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 2 SEPTEMBERZ2,2O2I
REQUEST NO.4l: The Company's response to Production Request No. l7 states that
the Company does not anticipate that battery adoption itself will lower volumetric sales and
reduce fixed cost recovery. Page 9 of the Application states that at the outset of the Wattsmart
Battery Program batteries will be dispatched to off-set customers' load as discussed in the Load
Shaping section. Please confirm that, at the outset of the program, batteries will be dispatched
for load shaping to off-set customer's peal load and will not lower the total load.
REQUEST NO. 42: The Company's response to Production Request No. l3 states that
the Company "will have control over the dispatch decisions for when batteries are used to offset
customer load based on current and future grid needs." Please answer the following questions.
a. Please explain what "dispatch decisions" mean. What kind of dispatch decisions
specifically will the Company have control over?
b. Between the Company and the customer, who will decide when the batteries will
be charged and who will decide when the batteries will be discharged?
c. Does the Company plan to use the batteries during peak hours only? Can the
batteries be used outside the peak hours? Please explain.
d. Will the customer be able to override any control for charging and discharging
decisions done by the Company? Please explain.
REQUEST NO. 43: The Company's response to Production Request No.14 (b) states
that it will be more challenging to get customers with existing solar to participate in the progrilm
than customers without existing solar (due to solar and battery combination packages being a
more attractive deal), thus requiring a lower incentive for customers who install solar on or after
September 1,2021. Please answer the following:
a. Please provide an economic analysis or other evidence to illustrate why
purchasing a battery separately is not as desirable.
b. Please explain how the additional $50/kW incentive for customers who install
solar before September 1,2021, was determined and why the amount is sufficient
REDACTED THIRD PRODUCTION REQUEST
TO ROCKY MOUNTATN POWER 3 SEPTEMBER22,2O2I
REQUEST NO. 44: The Company's response to Production Request No. 14 (e) states
that participation incentives are based on continuous output (kW) of the baffery which is
available to Rocky Mountain Power (RMP). Please define "continuous output" and describe
how it will be maintained and/or enforced.
REQUEST NO. 45: The Company's response to Production Request No. 15 states that
estimates provided in Table No. 2 and Table No. 3 in the Application assume batteries may be
used for all grid manasement applications. Please explain why these same estimates apply to the
initial phase (the load shaping phase).
REQUEST NO. 46: The Company's response to Production Request No. 16 states that
Table No. 1 in the Application (Wattsmart Battery Incentives) assumes batteries may be used for
all grid services. Please explain why the Company believes incentives for the initial phase (the
load shaping service) should be designed based on the assumption of all grid services before grid
services are determined as feasible or implemented.
REQUEST NO. 47: The Company's response to Production Request No. 17 states that
"customer-sited batteries rather change the timing of energy consumption and can increase
volumetric energy sales as efficiency losses are experienced." Please answer the following
questions.
a. Please define "efficiency losses".
b. Please explain why efficiency losses can cause volumetric energy sales to
lncrease.
REQUEST NO.48: Page 5 of the Application states that for residential customers, the
incentive with solar installed prior to September 2021will be the maximum amount of $150/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. Response to
Production Request No. 14 (c) states that this incentive structure applies to commercial
customers immediately as well.
REDACTED THIRD PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 4 SEPTEMBER22,2O2I
a.
b
c
d.
e. Please identifu in the Company's Exhibit B this proposed $100/kW enrollment
incentive structure or where the Company will identifu these specific
requirements around solar installations installed after August202l.
f. Additionally, of the Company's projected 600 total customers by 2024, please
identi$ how many of these customers will have received the enrollment incentive
of "$100/kW multiplied by the commitment term"?
REQUEST NO. 49:
REQUEST NO. 50:
REDACTED THIRD PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 5 SEPTEMBER22,2O2I
DATED at Boise,Idaho, 5rr22
Teohnioal Staff: Ta,ylor Thomas (36-39)
Brad Iverson-Long (40)
Yao Yin (41-50)
i:umire:prodrsdpaco2l.l6csbt ptod rcq 3
REDACTED TIIIRD PRODUCTION REQUEST
TO ROCKY MOTINTAIN PO\ITER 6
o
day of Septembs2A2l..
:,-,
Eriok Shaner
DepuffAttorney General
SEPTEMBER 22,2CI21
CERTIFICATE OF SERYICE
I HEREBY CERTIFY THAT I HAVE THIS 22"d DAY OF SEPTEMBER 2021,
SERVED THE FOREGOING REDACTED THIRD PRODUCTION REQT]EST OF
THE COMMISSION STAFF TO ROCKY MOUNTAIN POWE& IN CASE
NO. PAC-E-21.16, BY E-MAILING A COPY THEREOF, TO THE FOLLOWING:
TED WESTON
MICHAEL SNOW
ROCKY MOUNTAIN POWER
I4O7 WEST NORTH TEMPLE STE 330
SALT LAKE CITY UT 84I16
E-MAIL : ted.weston@ pacificorp. com
michael.snow@pacifi corp.com
DATA REQUEST RESPONSE CENTER
E.MAIL O]T[LY:
datareq uest@paci fi corp.com
EMILY WEGENER
ROCKY MOUNTAIN POWER
I4O7 WN TEMPLE STE 320
SALT LAKE CITY UT 84I 16
E-MAIL: [e-mail]
Y
CERTIFICATE OF SERVICE