20221129Staff 23-33 to PAC.pdf

MICHAEL DUVAL
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. II7I4
iiECiIVED
:t?i i{i}Y 29 PH 3: 57
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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 MOTJNTAIN POWER FOR
AUTHORITY TO IMPLEMENT A
COMMERCIAL AND INDUSTRIAL
DEMAND RE,SPONSE PROGRAM
CASE NO. PAC.E-22-I3
SECOND PRODUCTION
REQUEST OF THE
COMMISSION STAFF
TO ROCKY MOUNTAIN
POWER
Staff of the Idaho Public Utilities Commission, by and through its attomey 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, DECEMBER 20, 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 identifu the name, job title, location, and
telephone number of the record holder.
SECOND PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER
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1 NOVEMBER29,2022
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.23: Please provide estimates for the range in cost, inventory
requirements, O&M costs, product life, reliability, and any other assumptions for the remote-
controlled relays used for automated curtailment. Please provide any additional supporting
documentation or worksheets to support these estimates.
REQUEST NO. 24: Please describe the Company's process for recovering physical
devices if a participant drops out of the program. Please provide analysis of how the additional
costs associated with the retrieval of the device, if any, will affect the program's cost
effectiveness.
REQUEST NO.25: Please describe the incentive structures the Company considered
for the proposed program (i.e., individual rates for grid management functions such as peak load
reduction, contingency reserves, and frequency response, fixed annual incentive, etc.) and the
reasoning used to select the proposed fixed incentive structure.
REQUEST NO. 26: In Response to Production Request No. 8, the Company indicates
that the value of energy fluctuates in response to several market conditions. Please provide an
explanation of how the Company tracks the fluctuation of these values and provide the
workpapers detailing the valuation of the different grid management functions with all formulas
intact and enabled.
REQUEST NO. 27: Please explain how the Company intends to report on the proposed
program.
RJQUEST NO. 28: Please explain how the Company will evaluate and report the
performance and cost-efflectiveness of the program. Please include all metrics, such as cost,
savings, and any other metrics the Company plans to use in its evaluation.
SECOND PRODUCTION REQUEST
TO ROCKY MOI-INTAIN POWER 2 NOVEMBER29,2022
REQUEST NO. 29: Please explain the Company's intentions for evaluating the
program? (i.e., process and impact evaluations)
REQUEST NO. 30: In the confidential worksheet provided in Response to Production
Request No. 16, Utah export credit values for energy and capacity ("energy+cap") and
incremental reserves are provided and used to calculate the benefits for the proposed program.
Please answer the following questions related to the Utah export credit values.
a. Please describe the reasoning for using Utah values for an Idaho program.
b. Please identifu the risk associated with using Utah values for Idaho and how the
Company accounted for them.
c. Please provide workpapers for the energyfcap and incremental reserve export credit
values in electronic format with formulas intact. Please include a detailed description
and examples of how these values are calculated.
d. The Company uses the sum of 2022 energy*cap and incremental reserve export credit
values to calculate the benefitsin2023. Please explain why 2022 export credits are
used to calculate 2023 benefits.
REQUEST NO.31: Does the Company intend to use the Commercial and Industrial
Demand Response program as part of a "flexible load" program? If so, please explain the
Company's approach to the "flexible" load program. If not, please explain why the Company
has not considered this approach as part of its Demand Response program.
REQUEST NO. 32: Does the Company intend to use the Commercial and Industrial
Demand Response program to allow for intraday shifting of electricity use during hours with
high electricity prices or peak load (i.e. load shifting)? If so, please explain the Company's
approach to "load shifting" within the program. If not, please explain why the Company has not
considered this approach as part of its Demand Response program.
REQUEST NO.33: In reference to Table 6 on page 6 of the Application, please explain
why the values for Maximum Dispatch Hours, Maximum Events per year, and the Dispatch
SECOND PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER J NOVEMBER2g,2022
Duration for the Real-Time Program and the Advance Notice Program differ from or are not
shown in proposed changes to the load management flexible tariff identified in Exhibit B of the
Application.
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DATED at Boise, Idaho, tfrit ] 7 day of December 2A22.
Michael Duval
Deputy Attorney General
i:umisc:prodreq/pace22. I 3mdr\ijt prod req 2
SECOND PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 4 NOVEMBER29,2022
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 29TH DAY OF NOVEMBER 2022,
SERVED THE FOREGOING SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF TO ROCKY MOTINTAIN POWER, IN CASE NO.
PAC-E-22-13, BY E-MAILING A COPY THEREOF, TO THE FOLLOWING:
TED WESTON
MICHAEL S SNOW
ROCKY MOUNTAIN POWER
I4O7 WEST NORTH TEMPLE STE 330
SALT LAKE CITY UT 84I 16
E-MAIL : ted.weston@paci fi corp.com
micheal.snow@pacifi corp.com
DATA REQUEST RESPONSE CENTER
E-MAIL ONLY:
datarequest@paci fi corp.com
BRUBAKER & ASSOCIATES
BRIAN C. COLLINS
GREG MEYER
16690 SWINGLEY RIDGE RD., #I4O
CHESTERFIELD, MO 63017
E-MAIL bcollins@consullbaieom
[e-mail]
LANCE KAUFMAN, PH.D.
2623 NW BLUEBELL PLACE
CORVALLIS, OR 97330
E-MAIL: [e-mail]
JOE DALLAS
ROCKY MOUNTAIN POWER
825 NE MULTNOMAH ST, SUITE 2OOO
PORTLAND OR 97232
E-MAIL : j [e-mail]
THOMAS J. BUDGE
RACINE, OLSON PLLP
2OI E. CENTER
PO BOX 1391
POCATELLO, ID 83204.1391
E-MAIL : d @racineolson.com
ERIC L. OLSEN
ECHO HAWK & OLSEN PLLC
505 PERSHING AVE., SUITE 1OO
PO BOX 6119
POCATELLO,ID 83205
E-MAIL : [e-mail]
L,4A*
SECRETAflt'
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CERTIFICATE OF SERVTCE