20221101PAC to Staff 1-22.pdf

ROCKY MOUNTAIN
POWER
HEC E IVE D
?$?2 t{0Y - | Att ll: k6
ri; j.ilC PUtsLlC
: iTil iTilS COt{MlSSl0N
1407 W North Temple, Suite 330
Salt Lake City, Utah 84116
November 1,2022
Jan Noriyuki
Idaho Public Utilities Commission
472W. Washington
Boise, ID 83702-5918
ian.noriyuki @puc. idaho. sov (C)
RE: ID PAC-E-22-13
IPUC Set I (l-22)
Please find enclosed Rocky Mountain Power's Responses to IPUC lst Set Data Requests l-22.
Also provided is Attachment IPUC I l. The Confidential Attachment IPUC 16 is provided via
BOX. 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 ProcedureNo.6T -lnformation
Exempt from Public Review.
If you have any questions, please feel free to call me at [phone].
Sincerely,
--Jsl-J. Ted Weston
Manager, Regulation
Enclosures
PAC-E-22-13 / Rocky Mountain Power
November 1,2022
IPUC Data Request I
IPUC Data Request 1
Please explain and quantify how the commercial and industial demand response
program will directly benefit customers of Rocky Mountain Power in Idaho ttrat
are not part of the program.
Response to IPUC Data Request I
The 2021Integrated Resource Plan (IRP) selected commercial and industrial
demand response @R) resources in Idaho as part ofthe Company's preferred
portfolio. The preferred portfolio is an outcome of extensive stakeholder
engagement and optimization modeling in PLEXOS. The resources included in
the prefened portfolio represent a least cost, least risk portfolio of resources to
meet customer load. The marginal resource that would be procured in lieu of this
DR program is more expensive or risky and therefore more costly to all customers
in Idatro, even if they do not participate in the program.
Recordholder: Peter Schaffer
Sponsor:Bill Comeau
PAC-E-22-13 /Rocky Mountain Power
November 1,2022
IPUC Data Request 2
IPUC Data Request 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. Application at 2.
Response to IPUC Data Request 2
A demand response @R) product must be capable of responding within 50
seconds to be qualified for a frequency response resewe. North American Electric
Reliability Corporation (NERC) reliability standard BAL-003-3 requires sufficient
Frequency Response from a Balancing Authority (BA) or Frequency Response
Sharing Group. PacifiCorp is a member of Western Power Pool Frequency Response
Sharing Group. The defined Primary Response Evaluation Period is the first 50
seconds ofthe Frequency Response Event.
Recordholder:Shawn Grant
Sponsor:Bill Comeau
PAC-E-22-13 / Rocky Mountain Power
November 1,2022
IPUC Data Request 3
IPUC Data Request 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 indusfiry or Company referenced documentation supporting ttre
parameters. Application at 2.
Response to IPUC Data Request 3
North American Electricity Reliability Corporation (NERC) reliability standard
BAL-002-WECC-3 requires that resources for Contingency Reserve Obligations
are fully deployable within l0 minutes. Requiring seven minutes allows for
communication and response time.
Recordholder:Shawn Grant
Sponsor:Bill Comeau
PAC-E-22-13 /Rocky Mountain Power
November 1,2022
IPUC Data Request 4
IPUC Data Request 4
Please explain the rational for ttre lower initial offered incentive amount of
$100/kW if the customer is able to participate in Real Time Option. Application at
5.
Response to IPUC Data Request 4
Incentives are typically set at amounts the Company believes will spark
participation among customers. The Company believes the proposed incentives
amounts will produce the anticipated participation. However, given that the
proposed pro$am is new, incentive levels and participation will be monitored and
adjusted if needed to maintain participation levels
Recordholder: Shawn Grant
Sponsor:Bill Comeau
P AC-E-22-13 / Rocky Mountain Power
November 1,2022
IPUC DataRequest 5
IPUC Data Request 5
Please explain the rational for the lower initial offered incentive amount of
$100/kW if the customer is able to participate in Advance Notice Option.
Application at 5.
Response to IPUC Data Request 5
Please refer to the Comparry's response to IPUC Data Request 4.
Recordholder: Shawn Grant
Sponsor:Bill Comeau
P AC-E-Z}-I 3 / Rocky Mountain Power
November 1,2022
IPUC DataRequest 6
IPUC Dah Request 6
Please explain the rational forthe lower initial offered incentive amountof
$175&W ifthe customer is able to participate in both the Real Time and Advance
Notice Option. Application at 5.
Restrronse to IPUC Data Request 6
Please refer to the Company's rcsponse to IPU{ DataRequest 4.
Recordholder: Shawn Grant
Sponsor:Bill Comoau
PAC-E-22-13 / Rocky Mountain Power
November 1,2022
IPUC Data Request 7
IPUC Data Request 7
Please explain and quantify 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.
Response to IPUC Data Request 7
If a program participant committed I megawatts O[!V) of load to be available for
curtailment all 8,760 hours of the year and the Company called no events during
the year, the customer would receive a $100,000 incentive (1,000 kilowatts (kW)
x $100 per kW: $100,000). The MW committed to participate in the program
provide value as a contingency reserve even when events are not actively being
called.
Recordholder:Shawn Grant
Sponsor:Bill Comeau
PAC-E-22-13 /Rocky Mountain Power
November 1,2022
IPUC Data Request 8
IPUC Data Roquest 8
Is ttre value of peak load reduction, contingency reserves, frequency response, and
other gid services consistent throughout the year for the Company? If noL please
explain why the program incentives have fxed annual amounts.
Response to IPUC Data Request 8
The value for energy fluctuates depending on real-time market conditions.
Factors such as, but not limited to, temperafure, time, local generation consfiaints,
generation plant outages, weather, etc. impact the value of load. The fixed annual
incentive proposed in the program are a cost-effective amount for an annual
incentive basis.
Recordholder:Shawn Grant
Sponsor:Bill Comeau
PAC-E-22-13 / Rocky Mountain Power
November 1,2022
IPUC Data Request 9
IPUC Data Request 9
Please explain why the Wattsmart Business Demand Response Program should be
managed through a flexible tariffprocess. Application at 7. In providing the
Company response, please indicate the circumstances that would change the
amount of the incentive and how often this would occur.
Response to IPUC Data Request 9
Program offerings and incentive amounts are typically adjusted for reasons such
as program maturity, market tansformation, increased or decreased program
participation, cost effectiveness maintenance, PacifiCorp's lntegrated Resource
Plan (IRP), budget modifications, stakeholder feedback, etc. The frequency with
which these events occur is intermittent, even wittr mafure programs. Having a
flexible tariffwill help to manage this new progftm by enabling the Company to
make swift adjusftnents if needed via the flexible tariff process and reduce risk.
Recordholder:Shawn Grant
Sponsor:Bill Comeau
PAC-E-22-13 / Rocky Mountain Power
November 1,2022
IPUC Data Request l0
IPUC Data Request 10
Please provide the website link to the program incentives referenced wittrin the
tariff.
Response to IPUC Data Request 10
A website specifically dedicated to an Idaho commercial and industial program
will not be developed until the program has been approved by the Idaho Public
Utilities Commission (PUC).
As an example, please refer to the website link provided below to the commercial
and industial demand response (DR) program approved by the Public Service
Commission of Utah (IPSC):
Demand Response (rockymountainpower.net)
Recordholder:Shawn Grant
Sponsor:Bill Comeau
PAC-E-22-13 / Rocky Mountain Power
November 1,2022
IPUC Data Request I I
IPUC Data Request 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.
O) Program Name.(c) Participant Type (i.e. residential, commercial, industrial, irrigation, other).
(d) Participant Count by Participant Type.(e) Participant Commitment Period (i.e. full year, months, days, hours).(0 Program Dispatch Period.
(g) Dispatch Days.(h) Available Dispatch Hours.(i) Maximum Dispatch Hours.
0) Maximum Dispatch Events.(k) Dispatch Duration.
0) DispatchNotification.
(m) Incentive.(n) Methodology for Calculating the Participant Incentive.(o) Opt-out Count by Participant Type.(p) Penalty for Opt-Out.(q) Total Enrolled MW (Gross - at Generator) for 2021.(r) Average Realized Load MW (at Generator) for 2021.(s) Maximum Realized Load MW (at Generator) for 2021.
Response to IPUC Data Request 11
Currently approved demand response (DR) programs include Oregon,
Washington, Utah, and Idaho Irrigation Load Control programs, Utah Cool
Keeper program, Utah and Idaho Wattsmart Batteries programs, and Utah's
Wattsmart Business DR program. Please refer to Attachment IPUC I I for the
requested details for each of these programs.
Recordholder:Shawn Grant
Sponsor:Bill Comeau
PAC-E-22-13 / Rocky Mountain Power
November 1,2022
IPUC Data Request l2
IPUC Data Request 12
Please explain how each of the following program parameters were determined.
In the explanation please include: (l) the rationale used (basis); (2) the work
papers 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,
(0 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.
Response to IPUC Data Request 12
(a) The maximum incentive is a dollar value per kilowatt (kW) determined to be
cost effective based on the assumptions noted in Confidential Exhibit C in
Case No. PAC-E-22-13. The initially offered incentive is a cost effective
estimated amount anticipated to incent customers to participate. The incentive
may increase or decrease as the program matures to achieve program goals.
(b) Please refer to the Company's response to subpart (a) above.
(c) Please refer to the Company's response to subpart (a) above.
(d) The amounts in Table 4 are based on planning estimates, participation
estimates from Table 5, and contractual amounts from a third-party program
administrator.
(e) The estimates in Table 5 are based on potential commercial and industrial
customers in Idaho who have load that could participate in the proposed
demand response (DR) program.
(f) The program parameters were designed to avoid customer participation fatigue
P AC-E-22-1 3 / Rocky Mountain Power
November 1,2022
IPUC DataRequost 12
along with providing sufEcient value for the Company as a rpsource. The
maximtm dispatchhours may change astho Company gains nore eryerienoe
after theprogram is implemented ad attainprogram dataand customer
fedback
(g) Please referto tre Company's response to subpart (0 above.
(h) Please referto tre Company's response to zubpart (f) abwe.
(i) Please refer to the Company's reqponse to IPUC Data Request 16,
specifically Confidential Arachment IPUC 16.
Recordholder: Shawn Crant
Sponsor:Bill Comeau
PAC-E-22-13 / Rocky Mountain Power
November 1,2022
IPUC Data Request 13
IPUC Data Request 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?
Response to IPUC Data Request 13
The design and intent of the program is to provide an incentive to participants for
load available for curtailment. Customer incentives would be calculated based on
hourly availability. If load is available, customers would receive an incentive or
credit for being available. If ttrere is no load available during certain hours
customers would not receive an incentive for those hours.
Recordholder:Shawn Grant
Sponsor:Bill Comeau
PAC-E-22-13 / Rocky Mountain Power
November 1,2022
IPUC Data Request 14
IPUC Data Request 14
How can the incentive structure be modified to account for the time value of
capacity?
Response to IPUC Data Request 14
The incentive structure is based on an annual kilowatt (kW) perfornance.
Calculation of payment could theoretically weigh eligible loads by month or
hours where capacity is more or less valuable or likely to be needed. However, for
frequency response services, events are unpredictable and therefore differentiating
value by hour or month may not reflect the actual value or need for capacity in a
given hour of the year. Note: it is presently unknown how customers might
respond to such an incentive structure.
Recordholder:Shawn Grant
Sponsor:Bill Comeau
PAC-E-22-13 / Rocky Mountain Power
November 1,2022
IPUC DataRequest l5
IPUC Data Request 15
Why are the combined advanced notice and real time participants priced higher
than real time only participants?
Response to IPUC Data Request 15
Program participants who participate in the advance notice program and the real-
time program receive a higher incentive because the load can be used for more
demand response @R) use cases and therefore provide more value and flexibility
to the Company.
Recordholder:Shawn Grant
Sponsor:Bill Comeau
PAC-E-22-13 / Rocky Mountain Power
November 1,2022
IPUC Data Request 16
IPUC Data Request 16
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 ttre 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.
Response to IPUC Data Request 16
Please refer to Confidential Attachment IPUC 16.
Confidential information is provided subject to protection under IDAPA
31.01.01.067 and 31.01.01.233,the ldaho Public Utilities Commission's Rules of
Procedure No. 67 - Information Exempt from Public Review.
Recordholder: Shawn Grant
Sponsor:Bill Comeau
PAC-E-22-13 /Rocky Mountain Power
November 1,2022
IPUC Data Request 17
IPUC Data Request 17
How frequently (i.e., annually, quarterly, as needed, etc.) does the Company
expect to consider program changes?
Response to IPUC Data Request 17
Program changes are typically based on a variety of factors, including program
maturity, market transformation, increased or decreased program participation,
cost effectiveness maintenance, PacifiCorp's Integrated Resource Plan (IRP),
budget modifications, stakeholder feedback, etc. The frequency with which these
events occur is intermittent even with mature programs. Based on these factors,
and given that the proposed program will be new, the Company will consider
program changes on an as needed basis, which may be frequent or sparse
depending on how the program performs.
Recordholder:Shawn Grant
Sponsor:Bill Comeau
PAC-E-22-13 / Rocky Mountain Power
November 1,2022
IPUCDataRequest 18
IPUC Data Roquest 18
What ctiteria will the Company use to evaluate progxam changes?
Response to IPUC Data Request 18
The Companywill consider ite'nrs such as butnot limited to, program
participation, ineentive levels, customer satisfaction, PacifiCorp's Intograted
Resource Plan (IRP), program energy savings, cost effectiveness, budget
stakeholder Hback, markEt transformation, eto.
Recordholder:Shawn Grant
Sponsor:Bill Comeau
PAC-E-22-13 /Rocky Mountain Power
November 1,2022
IPUC Data Request 19
IPUC Data Request 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.
Response to IPUC Data Request 19
The Company contacted with a program administrator @nel X) who will be
responsible for equipment installation, technical configurations, and general
program management functions. Installations for automatic transfer switch will be
handled by Enel X and will require a customized configuration based on the site
and specific equipment to be curtailed. The estimated costs associated with the
installation per Enel X could be $1,500 to $2,000 per site. The Company is
assuming participation in Idaho from customers that can respond to frequency
response events that would require automatic nansfer swirches and/or frequency
relays to be low.
Recordholder:Shawn Grant
Sponsor:Bill Comeau
PAC-EA2-13 /Rocky Mountain Power
November 1,2022
IPUC DataRequest 20
IPUC Ilata Roqust 20
Please provide the reasoning for the propos€d dispatch period and available
dispatch hours.
Response to IPUC Data Request 20
The dispatch period is 24 hours.a-My, seven days-a-weeJg 365 days-a-year. A
comprehensive dispatch period is necessary to modmize tre benefits associated
with this program. The dispatch hours were based on erperience with prwious
progmms and prograrn retention.
Recordholder:Shawn Cnant
Sponsor:Bill Comeau
PAC-EA2-13 / Rocky Mountain Porrer
November 1,2022
IPUC DataRequest 21
IPUC Data Roquest 21
Please explain if thene any operational, differing prr,cesses, or othor dlfferEnces
between Demand Response plograms and Energy Effciency measunes for the
flexible ariffprooess.
Response to IPUC Dah Requect 21
There are no ditrering process€$ or other differences between
demand reqponse (DR) and energy efficiency (EE) pograms for the flexible tariff
prcoess.
Reoordtrolder: Shawn Grant
Sponsor:Bill Comeau
PAC-E-22-13 / Rocky Mountain Power
November 1,2022
IPUC Data Request 22
IPUC Data Request22
In the Company's Application, it is stated that the progftrm 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.
Response to IPUC Data Requst22
Other services cannot be fully defined or valued at this time. As the program
evolves and the grid fiansitions over time, the Company will look for
opportunities to utilize demand response @R) programs for additional grid
services as they apply. Any changes to DR programs will be implemented in
compliance with regulatory and flexible tariffprocesses.
Recordholder:Shawn Grant
Sponsor:Bill Comeau