20221011Staff 1-22 to PAC.pdf

MICHAEL DUVAL
DEPUTY ATTORNEY GENERAL
IDAHO PUBLTC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BARNO. 11714
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Street Address for Express Mail:
I 133I W CHINDEN BLVD, BLDG 8, SUITE 2OI-A
BOISE, TD 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
COMMERCIAL AI\D INDUSTRIAL DEMAI\D
RESPONSE PROGRAM
CASE NO. PAC-8.22.I3
FIRST PRODUCTION
REQUEST OF THE
COMMISSION STAFF
TO ROCKY MOUNTAIN
POWER
Staff of the Idaho Public Utilities Commission, by and through its attorney of record,
Michael Duval, Deputy Attorney General, requests that Rocky Mountain Power ("Company")
provide the following documents and information as soon as possible, but no later than
TUESDAY, NOVEMBER 1, 2022.
This Production Request is to be considered as continuing, and the Company 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 also identifr the name, job title, location, and
telephone number of the record holder.
FIRST PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER
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I ocroBER 1t,2022
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. 1: Please explain and quantifu how the commercial and industrial
demand response program will directly benefit customers of Rocky Mountain Power in Idaho
that are not part of the program.
REQUEST NO.2: Please explain the rationale for considering automated dispatch
without advance notice with a total response time within 50 seconds as being considered a real-
time event. Please provide industry or Company referenced documentation supporting these
parameters. Applicati on at 2.
REQUEST NO.3: Please explain the rationale for considering a dispatched event with
an advanced notice and a response within 7 minutes to be considered an advanced notice event.
Please provide industry or Company referenced documentation supporting the parameters.
Application at 2.
REQUEST NO. 4: Please explain the rational for the lower initial offered incentive
amount of $100/kW if the customer is able to participate in Real Time Option. Application at 5
REQUEST NO. 5: Please explain the rational for the lower initial offered incentive
amount of $100ikW if the customer is able to participate in Advance Notice Option. Application
at 5.
REQUEST NO. 6: Please explain the rational for the lower initial offered incentive
amount of $175&W if the customer is able to participate in both the Real Time and Advance
Notice Option. Application at 5.
REQUEST NO. 7: Please explain and quantifu the amount of incentive a participant in
the Demand Response program would receive if no events were called during the program year.
Application at 5.
FIRST PRODUCTTON REQUEST
TO ROCKY MOUNTAIN POWER 2 ocToBER 11,2022
REQUEST NO.8: Is the value of peak load reduction, contingency reserves, frequency
response, and other grid services consistent throughout the year for the Company? If not, please
explain why the program incentives have fixed annual amounts.
REQUEST NO. 9: Please explain why the Wattsmart Business Demand Response
Program should be managed through a flexible tariff process. Application at 7. [n providing the
Company response, please indicate the circumstances that would change the amount of the
incentive and how often this would occur.
REQUEST NO. l0: Please provide the website link to the program incentives
referenced within the tariff.
REQUEST NO. 11: Please provide a listing of all current PacifiCorp Demand Response
programs. The listing should identify each of the following items below:
a. Jurisdiction/State
b. Program Name
c. Participant Type (i.e. residential, commercial, industrial, inigation, other)
d. Participant Count by Participant Type
e. Participant Commitment Period (i.e. full year, months, days, hours)
f. Program Dispatch Period
g. Dispatch Days
h. Available Dispatch Hours
i. Maximum Dispatch Hours
j. Maximum Dispatch Events
k. Dispatch Duration
l. DispatchNotification
m. Incentive
n. Methodology for Calculating the Participant lncentive
o. Opt-out Count by Participant Type
p. Penalty for Opt-Out
q. Total Enrolled MW (Gross - at Generator) for 2021
FIRST PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER J ocToBER t1,2022
r. Average Realized Load MW (at Generator) for 2021
s. Maximum Realized Load MW (at Generator) for 2021
REQUEST NO. 12: Please explain how each of the following program parameters were
determined. In the explanation please include: (l) the rationale used (basis); (2) the workpapers
of the calculations (or by using an example where appropriate); (3) the specific source of
information for any inputs.
a. initial and maximum incentives for real time option (Table No. 3),
b. initial and maximum incentives for advance notice option (Table No. 3),
c. initial and maximum incentives for real time/advance notice option (Table No. 3),
d. the amounts in Table No. 4,
e. the amounts in Table No. 5,
f. maximum dispatch hours for real time and advance notice programs,
g. maximum events per year for the real time and advance notice programs,
h. dispatch duration for the real time and advanced notice programs, and
i. the avoided cost used in the cost/benefit analysis in exhibit C.
REQUEST NO. 13: Why does the capacity factor not include when a customer's load is
available for curtailment given that some customer's loads may occur only when the Company
has the highest amount of excess capacity?
REQUEST NO. 14: How can the incentive structure be modified to account for the time
value of capaciq?
REQUEST NO. 15: Why are the combined advanced notice and real time participants
priced higher than real time only participants?
REQUEST NO. 16: For the Company's cost-effectiveness calculation provided in
Exhibit C, please provide the following in Excel format with all formulas enabled:
FIRST PRODUCTION REQUEST
TO ROCKY MOUNTATN POWER 4 ocToBER 11,2022
a. Please provide all workpapers for the cost effectiveness study shown in Exhibit C
including all modeled assumptions;
b. Please provide the Company's benefits calculation for each year for the entire analysis
period;
c. Please provide the benefits calculations from the Utility Cost Test ("UCT")
perspective; and
d. Please provide the avoided cost used for the Company's benefits calculations and
brief explanation of how the Company calculates the avoided cost.
REQUEST NO. 17: How frequently (i.e., annually, quarterly, as needed, etc.) does the
Company expect to consider program changes?
REQUEST NO. 18: What criteria will the Company use to evaluate program changes?
REQUEST NO. 19: Please provide estimates for the cost range, inventory requirements,
O&M costs, reliability, and any other assumptions for the automatic transfer switches and
frequency relays. Please provide any additional documentation or worksheets to support these
estimates.
REQUEST NO. 20: Please provide the reasoning for the proposed dispatch period and
available dispatch hours.
REQUEST NO. 21: Please explain if there any operational, differing processes, or other
differences between Demand Response programs and Energy Efficiency measures for the
fl exible tariff process.
REQUEST NO. 22: In the Company's Application, it is stated that the program may be
used to provide other grid services. Application at 2. Please describe these other services and
their value to the proposed Demand Response program.
FIRST PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 5 ocToBER 11,2022
DATED at Boise, Idaho, this llfh AuyofOctober 2022.
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Michael Duval
Deputy Attorney General
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FIRST PRODUCTION REQUEST
TO ROCKY IIVIOIJNTAIN POWER 6 ocToBER ll,2a22
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS llTH DAY OF OCTOBER 2022,
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF TIIE
CoMMISSION STAFF TO ROCKY MOUNTAIN POWER, IN CASE NO.
PAC-8.22.I3, BY E-MAILING A COPY THEREOF, TO THE FOLLOWING:
TED WESTON
ROCKY MOUNTAIN POWER
I4O7 WEST NORTH TEMPLE STE 330
SALT LAKE CITY UT 84116
E-MAIL : [e-mail]
DATA REQUEST RESPONSE CENTER
E.MAIL ONLY:
datarequest@pacifi com.com
MICHAEL S SNOW
ROCKY MOUNTAIN POWER
I4O7 WN TEMPLE STE 320
SALT LAKE CITY UT 84116
E-MAIL: micheal.snow@pacifi com.com
SECRETAR
CERTIFICATE OF SERVICE