20211013PAC to Staff 36-50-Redacted.pdf

ROCKY MOUNTAIN
POWER
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October 13,2021
Jan Noriyuki
Idatro Public Utilities Commission
472W. Washington
Boise, ID 83702-5918
ian.norivuki@puc. idaho.sov (C)
RE: ID PAC-E-21-16
IPUC Set 3 (36-50)
Please furd enclosed Rocky Mountain Power's Responses to IPUC 3d Set Data Requests 36-50.
Also provided is Attachment IPUC 37. Provided via encryption are Confidential Responses
IPUC 48-50. Confidential information is provided subject to protection under TDAPA
31.01.01.067 and 31.01.01.233, ttre Idaho Public Utilities Commission's Rules of Procedure No.
67 - Information Exempt from Public Review, and further subject to the Non-Disclosure
Agreement (NDA) executed in this proceeding.
If you have any questions, please feel free to call me at [phone].
Sincerely,
-Jsl-J. Ted Weston
Manager, Regulation
Enclosures
PAC-E-21-16 / Rocky Mountain Power
October 13,2021
IPUC DataRequest 36
IPUC Data Request 36
In the Company's Wattsmart Battery progftm in Utah, the Company's website
states, "batteries will not be controlled daily from November through February."
Is this the Company's intent for the Wattsmart Battery program in ldaho as well?
Please explain.
Response to IPUC Data Request 36
At the beginning of the program, it is the Company's intent not to contol the
batteries daily from November through February. As the Company gathers more
experience with batteries, the confiol schedule will be modified to best meet the
needs of customers and the Company.
Recordholder: Shawn Grant
Sponsor:Bill Comeau
PAC-E-21-16 / Rocky Mountain Power
October 13,2021
IPUC Data Request 37
IPUC Data Request 37
The Company's cost-effectiveness calculation is modeled using a 20-year
measure life; however, the batteries are required to have a minimum of a l0-year
life. Please explain the reasoning for modeling the battery measure life for 20-
years. In the response, please provide supporting documents, workpapers, and/or
research that supports a}D-year battery measure life. Please also indicate the
battery type being modeled.
Response to IPUC Data Request 37
To clariff, for batteries to be eligible for the program, batteries are required to
have l0-year minimum warranty; not a minimum lO-year battery life. Battery
technology is expected to last beyond the manufacturer's wananty. The program
modeled Sonnen Core, Sonnen Eco, and Sonnen Ecolinx batteries. Please refer to
Attachment IPUC 37 which provides technical specification sheets for these
batteries.
Recordholder:Shawn Grant
Sponsor:Bill Comeau
PAC-E-21-16 / Rocky Mountain Power
October 13,2021
IPUC Data Request 38
IPUC Data Request 38
The Company's response to Production Request No. 26 (c) states "for select
batteries, the current technology is suffrcient to meet the energy needs for
advanced demand response." Please explain advanced demand response. How
does advanced demand response differ from taditional demand response?
Response to IPUC Data Request 3E
Traditional demand response events are typically pre-scheduled day ahead or
several hours in advance when system load is expected to peak. Generally, these
events occur mid-afternoon when temperatures are high during summer months.
The Wattsmart Battery Program is connected directly into the Company's Energy
Management System (EMS) providing a flexible resource which is automatically
dispatched real-time to respond to large grid events with frequency response. In
addition, it can be utilized for contingency reserves, peak load management, and
for daily storing of solar energy during ttre day for use during peak times in the
evenings and mornings.
Recordholder:Shawn Grant
Sponsor:Bill Comeau
PAC-E-21-16 / Rocky Mountain Power
October 13,2021
IPUC Data Request 39
IPUC Data Request 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?
Response to IPUC Data Request 39
To integrate into the Company's Distributed Battery Grid Management
System (DBGMS) and be eligible for participation, batteries must meet the
following minimum requirements :
Ability to be contolled remotely using a PC or MAC address;
Ability to accept extemal control commands from the Company's
DBGMS and conform to its Application Programming Interface (API)
standards;
Must support PacifiCorp Institute of Electical and Electronic Engineers
(IEEE) 2030.5 protocol;
Must meet Underwriters Laboratories (UL) safety certifications for UL
9540, 9540A, 1973, I 74 l -CRD PCS, and/or I 74 l -SA;
Organization that designed and manufactured the battery system must be
International Organization for Standardization (l SO) 900 I certifi ed ;
Requires real-time data forecasting; and
Requires real-time response (0-30 seconds).
Requirements are listed on the Company's website and in the Battery Vendor
Application form linked on the website:
https://www.rockvmountainpower.net/savings-energv-choices/utah-wattsmart-
battery-proq ram/batterv-man u factu rers. htm l
Recordholder: Shawn Grant
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Sponsor:Bill Comeau
PAC-E-21-16 / Rocky Mountain Power
October 13,2021
IPUC Data Request 40
IPUC Data Request 40
Regarding the Company's response to Production Request No. 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 program during
these events that are expected to cause system outages.
Response to IPUC Data Request 40
The criteria to determine whether events warrant minimizing Wattsmart Battery
dispatch events will be developed as the Company collects battery data and
experience from program participants. Due to the real-time aspect of the program,
the Company does not provide advance notification to customers for battery
dispatch events.
Recordholder:Shawn Grant
Sponsor:Bill Comeau
PAC-E-21-16 / Rocky Mountain Power
October 13,2021
IPUC Data Request 4l
IPUC Data Request 41
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 offiset customer's
peak load and will not lower the total load.
Response to IPUC Data Request 4l
Confirmed - batteries will be dispatched for load shaping to oftset customer's
peak load and will not lower the total load. In addition, batteries will also be
used for other grid needs, including but not limited to, frequency response,
backup power, traditional demand response, contingency reserves, etc.
Recordholder:Shawn Grant
Sponsor:Bill Comeau
PAC-E-21-16 / Rocky Mountain Power
October 13,2021
IPUC Data Request 42
IPUC Data Request 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 controlover?
(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 conftol for charging and discharging
decisions done by the Company? Please explain.
Response to IPUC Data Request 42
(a) Dispatch decision means when the batteries willbe activated. The Company
will have control over when the battery is used to support customers' homes
or the grid.
(b) The Company will decide when the batteries will be charged or discharged,
however the intent is for batteries to be charged regularly by excess customer
solar generation.
(c) The batteries are expected to be available and may be utilized 2417,365 days a
yeat.
(d) The current design of the program does not allow a customer to override
control of their battery, except for the safety disconnect that can be used by
the customer or fire deparhnent.
Recordholder:Shawn Grant
Sponsor:BillComeau
PAC-E-21-16 / Rocky Mountain Power
October 13,2021
IPUC Data Request 43
IPUC Data Request 43
The Company's response to Production Request No. I 4 (b) states that it will be
more challenging to get customers with existing solar to participate in the
program 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.
Response to IPUC Data Request 43
(a) Purchasing solar/battery combination or standalone battery generally is more
than a financial economic decision. Each home and consumer are different,
and the homeowner needs to determine if purchasing and installing a battery is
the right purchase for their unique situation. Generally, it costs more to add a
battery to existing solar than to install a battery and solar at the same time due
to additional labor and equipment costs.
(b) To clariff, the September I't date from the Company's Application was
included when it was anticipated the program may be effective in October
2021. However, now that the program's effective date has been pushed to
what will likely be the first quarter of 2022, the additional $50/kW incentive
will be applicable to customers who install solar before the effective date of
the program, rather than the previously stated September I't date.
The incentive amounts were determined through planning assumptions,
available budget, estimated participation, available equipment, etc. Incentives
will be reviewed periodically to determine if they are sufficient to increase
battery adoption and participation in the program or if adjustments are needed.
Recordholder:Shawn Grant
Sponsor:Bill Comeau
PAC-E-21-16 / Rocky Mountain Power
October 13,2021
IPUC DataRequest 44
IPUC Data Request 44
The Company's response to Production Request No. 14 (e) states that
participation incentives are based on continuous output ftW) of the battery which
is available to Rocky Mountain Power (RMP). Please define "continuous outpuf'
and describe how it will be maintained and/or enforced.
Response to IPUC Data Request 44
Continuous output is the output kilowatts (kW) of the battery that is accessible to
the Company over a continuous timeframe. For example, if a customer installs a
battery rated as a 5 kW continuous output with a l0 kilowatt-hour (kWh) storage
capacrty, the battery would continually output 5 kW for two hours. Batteries
enrolled in the program will have performance data visible through the
Distributed Battery Grid Management System (DBGMS).
Recordholder:Shawn Grant
Sponsor:Bill Comeau
PAC-E-21-16 / Rocky Mountain Power
October 13,2021
IPUC Data Request 45
IPUC Data Request 45
The Company's response to Production RequestNo. l5 states that estimates
provided in Table No. 2 and Table No. 3 in the Application :rssume bafferies may
be used for all grid management applications. Please explain why these same
estimates apply to the initial phase (the load shaping phase).
Response to IPUC Data Request 45
The initial phase includes the grid services listed in the application. The second
phase will incorporate lessons learned from operation of the Program and
customer experience.
Recordholder: Shawn Grant
Sponsor:Bill Comeau
PAC-E-21-16 / Rocky Mountain Power
October 13,2021
IPUC DataRequest46
IPUC Datr Request 46
The Company's response to Production RequestNo. 16 states that Table No. I in
the Application (Wattsmart Battery Incentives) assumes batterios 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.
Recponse to IPUC Deta Request 46
The initial phase includes the grid serviees listed in the application.
Recordholder: Shawn Crrant
Sponsor:Bill Comeau
PAC-E-21-16 / Rocky Mountain Power
October 13,2021
IPUC Data Request 47
IPUC Data Request 47
The Company's response to Production RequestNo. l7 states that "customer-
sited batteries rather change the timing of energy consumption and can increase
volumetic energy sales as effrciency losses are experienced." Please answer the
following questions.
(a) Please defne "efficiency losses"
(b) Please explain why efficiency losses can cause volumetric energy sales to
increase.
Response to IPUC Data Requst 47
(a) Efficiency losses are the energy losses that occur from charging and
discharging a battery. This is sometimes referred to as round-fiip effrciency.
(b) All else equal, if a customer adopts a battery and charges and discharges it at
different times, more energy will be consumed because of the consequent
energy losses.
Recordholder: Robert Meredith
Sponsor:Robert Meredith
PAC-E-21-16 / Rocky Mountain Power
October 13,2021
IPUC Data Request 48
IPUC Data Request 48
CONFIDENTIAL REQUEST - Page 5 of the Application states that for
residential customers, the incentive with solar installed prior to September 2021
will be the maximum amount of $150/kW multiplied by the commitment term.
The offered incentive for customers with solar installed after August 2021 will be
set at $100&W multiplied by the commitment term. Response to Production
Request No. l4(c) states that this incentive structure applies to commercial
customers immediately as well.
(e) Please identiff in the Company's Exhibit B this proposed $100/kW enrollment
incentive structure or where the Company will identiff these specific
requirements around solar installations installed after August 2021.
(0 Additionally, of the Company's projected 600 total customers by 2024, please
identiff how many of these customers will have received the enrollment
incentive of "$100/kW multiplied by the commitment term"?
PAC-E-21-16 / Rocky Mountain Power
October 13,2021
IPUC Data Request 48
Confidential Response to IPUC Data Request 48
(a) For cost effectiveness calculation the higher incentive amount was modeled to
ensure the program would be cost effective. If the program is cost effective at
the higher incentive amount it is assumed to be cost effective at the lower
incentive amount. The Company anticipates battery adoption will increase
during the next few years. As a result, technology will improve, prices may
decrease, and a higher incentive is not forecasted for battery adoption and
program participation to occur. Incentives are designed to motivate customers
to participate who otherwise would not without the financial incentive.
(b) Confinned.
(c) The Company anticipates adoption of commercial batteries will be slower due
to limited options and technology currently available in the market.
(d) Based on the
was year
(e) All program and incentive information for current offerings approved in the
Company's program tariffwill be maintained on the Company's website.
(f1 It is not known how many customers with existing solar will choose to
participate in the program, but could range between l0 and 50 percent or more
of the projected customer participation.
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 further subject
to the Non-Disclosure Agreement (NDA) executed in this proceeding.
Recordholder:Shawn Grant
Sponsor:Bill Comeau
PAC-E-21-16 / Rocky Mountain Power
October 13,2021
IPUC Data Request 49
IPUC Data Request 49
CONFIDENTIAL REQIIEST - ln the Confidential File "Attach IPUC 5 Conf'
in the to Production No.
Response to IPUC Data Request 49
The "lncentive Planning" and "10 year" tabs were utilized for various
hypothetical modeling scenarios and various planning assumptions. The data
included in these tabs and other tabs are working papers.
Recordholder:Shawn Grant
Sponsor:Bill Comeau
PAC-E-21-16 / Rocky Mountain Power
October 13,2021
IPUC Data Request 50
IPUC Data Request 50
- Please the basis and how the
Response to IPUC Data Request 50
PacifiCorp's 20l9Integrated Resource Plan (IRP) model simulations and cost
data reflect PacifiCorp's corporate inflation rate schedule unless othenuise noted.
A single annual escalation rate value of 2.28 percent is assumed. The annual
escalation rate reflects the average of annual inflation rate projections for the
period 2019 through 2038, using PacifiCorp's September 2018 inflation curve.
PacifrCorp's inflation curve is a sfraight average of forecasts for the Gross
Domestic Product (GDP) inflator and the Consumer Price Index (CPD.
Please refer to the 2019 IRP, Volume I, page 179. PacifiCorp's 2019IRP is
publicly available and can be accessed by utilizing the following website link:
Integrated Resource Plan (pacificom.com)
Recordholder: Shawn Grant
Sponsor:Bill Comeau