20221222PAC to Staff 23-33 - Redacted.pdf

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1407 W North Temple, Suite 330
Salt Lake City, Utah 84116
December 22,2022
Jan Noriyuki
Idatro Public Utilities Commission
472W. Washington
Boise, ID 83702-5918
[e-mail]. gov (C)
RE D PAC-E-22-13
IPUC Set 2 (23-33)
Please find enclosed Rocky Mountain Power's Responses to IPUC 2d Set Data Requests 23-33.
The Confidential Reqponse to Data Request IPUC 23 and Confidential Attachment IPUC ?.6 are
provided via BOX. Confidential information is provided subject to protection under IDAPA
31.01.01.067 and 31.01.01.233,the Idatro Public Utilities Commission's Rules of Procedure No.
67 - Information Exempt from Public Review.
If you have any questions, please feel free to call me at [phone]
Sincerely,
--Jsl-Mark Alder
Manager, Regulation
Enclosures
PAC-E-22-13 / Rocky Mountain Power
December 22,2022
IPUC Data Request 23
IPUC Data Request 23
Please provide estimates for the range in cost, inventory requirements, O&M
costs, product life, reliability, and any other assumptions for the remote conftolled
relays used for automated curtailment. Please provide any additional supporting
documentation or worksheets to support these estimates.
Confidential Response to IPUC Data Request 23
for
per
set-up any other
costs related to installing and maintaining equipment for automated contols
and/or manual controls. If there is a need for additional equipment at a site, it
would require a custom bid based on the specific location and/or equipment.
Confidential information is provided subject to protection under TDAPA
31.01.01.067 and 31.01.01.233,the Idaho Public Utilities Commission's Rules of
Procedure No. 67 - lnformation Exempt from Public Review.
Recordholder:Shawn Grant
Sponsor:Clay Monroe
PAC-E-22-13 / Rocky Mounain Power
December 22,2022
IPUC DataRequest 24
IPUC Data Request24
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 retieval of the device, if any, will affect the
program's cost effectiveness.
Response to IPUC Data Requst24
To recover physical devices from previous program participant, the equipment
would either be uninstalled by on-site maintenance staff, by a third-party program
administator, or by Company staff. The costs to retieve ttrese devices would be
minimal and would be expected to have an immaterial impact to overall program
cost effectiveness.
Recordholder: Shawn Grant
Sponsor:Clay Monroe
PAC-E-22-13 / Rocky Mountain Power
December 22,2022
IPUC DataRequest 25
IPUC Data Request 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 reseryes, and frequency response, fixed annual incentive,
etc.) and the reasoning used to select the proposed fxed incentive sfucture.
Response to IPUC Data Request 25
The proposed fixed incentive structure for this demand response @R) program
was ultimately selected for cost effectiveness and customer experience. The
Company considered offering different incentive values based on different hours,
days, and months of the year. The Company considered developing a
sophisticated incentive structure for different use cases and hourly rates
throughout the year. Ultimately, the Company determined a sophisticated
incentive stucture would be a deterrent for customer participation. An easy-to-
understand fixed incentive stucture is expected to be the best option for program
adoption and success.
Recordholder:Shawn Crrant
Sponsor:Clay Monroe
PAC-E-22-13 / Rocky Mountain Power
December 22,2022
IPUC DataRequest 26
IPUC Data Request 26
ln Response to Production Request No. 8, the Company indicates that the value of
energy flucfuates in response to several market conditions. Please provide an
explanation of how the Company facks the fluctuation of these values and
provide the workpapers detailing the valuation ofthe different grid management
functions with all formulas intact and enabled.
Response to IPUC Data Request 26
Real-time operations' monitors reserve holdings and locational marginal prices
(Lt{P) on a continuous basis. Operators use the energy management system
(EMS) and Pi Historian to monitor total reserve holdings to determine sufficiency
meeting reserve obligations as a member of the Western Power Pool Reserve
(WPP) Sharing Group. Operators monitor individual resources for performance
and demand response @R) programs holding reserves using the EMS, Pi
Historian, and the Yukon application which administers flre CoolKeeper progftlm.
Additionally, real-time operations' monitors LMP for energy using SettleCore
software and California Independent System Operator (CAISO) applications.
The Company's current process for DR valuation generally work as follows:
Contingency Reserves - to count as contingency reserve, resources must respond
within l0 minutes following a loss of generation or transmission. These events
typically last less than 60 minutes. The Company has a number of different load
control resources that could be deployed and depending on the magnitude of the
need and contractual details related to the frequency and duration of events,
system operators will deploy one or more resources when an event occurs. On a
forecast basis, the Company's Integrated Resource Plan (IRP) production cost
modeling tool, PLEXOS, reports the marginal cost of holding contingency
reserves on an hourly basis, and the results from the IRP preferred portfolio are
used for DR program analysis.
Frequency Response - to count as frequency response, resources must respond
within seconds to a dip in the frequency of the Westem lnterconnect. The
Company currently has automated processes which deploy the Coolkeeper Air
Conditioning Confrol progtam in response to frequency events. These events
typically last less than l0 minutes. When they are enabled for frequency response,
all available frequency responsive resources respond automatically to frequency
events. The PLEXOS model is not configured to account for frequency reqponse
requirements, which overlap with spinning reserves.
Energy, peak load reduction, and other grid services - when DR is available
and not being held ready for one of the short-notice reserve products above, it can
be deployed to provide energy value, which may occur during peak load periods.
PAC-E-22-13 / Rocky Mountain Power
December 22,2022
IPUC DataRequest 26
To the extent the Company has DR available to call on, it can avoid market
purchases or not start-up thermal resources that might be needed to cover peak
load hours. The PLEXOS model reports the marginal energy cost by location, and
results from the IRP preferred portfolio arc used for DR program analysis.
Please refer to Confidential Attachment IPUC 26 which provides the work paper
detailing the Company's valuation of the grid management functions.
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.
Recordholder: Peter Schaffer
Sponsor:Clay Monroe
PAC-F-22-13 /Rocky Mountain Power
December 22,2022
IPUC DataRequest 27
IPUC Deb Requellt27
Please exphin how the Company intends to report on the proposed progam.
Responce to IPUC Data Requ6t27
Ifthe proposed program is approvedn the Company intends to report on the
prcgram annually within the pro-existing Demand-Side Managenrent (DSM)
Annual Report, consistentwith otherde,nrand rcsponse (DR) program r€porting.
Reordholder: Shawn Ctrant
Sponsor:CIay Monroe
PAC-E-22-13 / Rocky Mountain Power
December 22,2022
IPUC DataRequest 28
IPUC Data Request 28
Please explain how the Company will evaluate and report the performance and
cost-effectiveness of the program. Please include all metics, such as cost,
savings, and any ottrer metics the Company plans to use in its evaluation.
Response to IPUC Data Request 28
The Company will consult with third-party evaluators to determine the best
methodology for evaluating the proposed commercial and industial demand
response @R) program. It is anticipated the evaluation will include items such as
kilowatt ftW) savings, cost effectiveness, customer experience, etc.
Recordholder:Shawn Grant
Sponsor:Clay Monroe
P AC-EA2-13 / Rocky Mountain Power
December 22,2022
IPUC DataRequest 29
IPUC DeteRoqust29
Please explain the Company's intentions for evaluating the program? (i.e., process
and impact evaluations)
Reoponse to IPUC Dato Rquest 29
The Company intmdsto discuss evaluation options in fifitre stakeholder meetings
with Idatro Public Utilities Commission (PUC) *aff. The pregram would need to
have zufficient participation levels before an evaluation would provide
meaningful data.
Recordtrolder: Shawn Grant
Sponsor:Clay Monroe
PAC-E-22-13 / Rocky Mountain Power
December 22,2022
IPUC Data Request 30
IPUC Data Request 30
In the confidential worksheet provided in Response to Production RequestNo. 16,
Utatr export credit values for energy and capacity (energy+s6p) and incremental
resewes are provided and used to calculate the benefits for ttre 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 ldatro progftm.
(b) Please identiff the risk associated with using Utah values for Idaho and how
the Company accounted for them.
(c) Please provide work papers for the energy*cap and incremental reserve export
credit values in electonic 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 benefits lrl.2023. Please explain why 2022
export credits are used to calculate 2023 benefrts.
Response to IPUC Data Request 30
(a) An Idaho-specific value for commercial and industrial demand response
@R) was not available at the time of filing. The Company utilized the
calculated value for Utah to calculate an estimated cost effectiveness for the
proposed program. Idaho-specific values were developed for cost
effectiveness for this proposed program and recalculated to ensure the
proposed program is still cost effective. Please refer to the Company's
response to IPUC Data Request 26, specifically Confidential Attachment
IPUC 26, which provides a copy of the work paper supporting the
development of ldaho-specific values.
(b) The risks of using Utah-specific values to estimate proposed cost
effectiveness are limited. [t was assumed the values for Idaho would be
very similar to values calculated for Utah as market prices for energy and
reserves are relatively similar between the two states.
(c) Please refer to the Company's response to IPUC Data Request 26,
specifically Confidential Attachment IPUC 26, which provides a copy of
the work paper supporting the development of ldaho-specific energy+cap
and incremental reserve values.
(d) The Company proposed cost effectiveness assuming five years of cumulative
megawatts (MW) for curtaihnent along with five years of total program costs.
The Company elected to use annual values starting with2022 values, with the
PAC-&22-13 / Rocky Mountain Power
Dmember 22,2022
IPUC DataRquest 30
assumption curmtvalues would be more accura@ than values five years into
ttre future. In lieu ofUtah elport oledit values, Idaho-specific values were
developed for eost effectiveness forthis proposd program and recalculated
to ensure tho proposed program is still cost effective. Please reforto the
Company's rcsponse to IPUC Data Request 26, speoifically Confidential
Attaehmot IPUC 26, which provides & oopy of the work paper suppotting
the development of ldalro-specific values.
Recordholden Shawn Crrart
Sponsor:Clay Monroe
PAC-E-22-13 / Rocky Mountain Power
December 22,2022
IPUC Data Request 3l
IPUC Data Request 31
Does the Company intend to use the Commercial and [ndustrial 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.
Response to IPUC Data Request 31
The Company's interprets "flexible load" to mean loads that can shift the timing
of demand, or modiff the timing of demand, to optimize based on prices,
emissions, or other priorities. Based on the foregoing interpretation, the Company
responds as follows:
The proposed program was designed for customers who have consistent load
available for curtailment. Customers are compensated based on their specific load
available for curtailment throughout a calendar year and participation in
scheduled events. Customers who have "flexible load" may participate in the
proposed program. Depending on the type of customers who have "flexible load"
may or may not be a good fit for a real-time program depending on the flexibility
of their industry (e.g. start and stop production lines, real-time modification of
business operations, etc.).
Recordholder:Shawn Grant
Sponsor:Clay Monroe
PAC-E-22-13 /Rocky Mountain Power
December 22,2022
IPUC Data Request 32
IPUC Data Request 32
Does the Company intend to use the Commercial and Industial Demand
Response progmln to allow for intraday shifting of electricity use during hours
wittr high elecricity 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.
Response to IPUC Data Request 32
The Company interprets "load shifting" to include time-of-day (TOD) rates, on-
peak rates / off-peak rates, and market-based rates. Based on the foregoing
inteqpretation, the Company responds as follows:
The initial design of the program did not consider "load shifting" as the program
was designed to curtail customer load (megawatts (MW) from the electric grid
when activated.
Recordholder:Shawn Grant
Sponsor:Clay Monroe
PAC-E-22-13 / Rocky Mountain Power
December 22,2022
IPUC DataRequest 33
IPUC Data Request 33
In reference to Table 6 on page 6 ofthe Application, please explain
why the values for Maximum Dispatch Hours, Maximum Events per year, and the
Dispatch Duration for the Real-Time Program and the AdvanceNotice Program
differ from or are not shown in proposed changes to the load management flexible
tariff identified in Exhibit B of the Application.
Response to IPUC Data Request 33
Table 6 of the Company's Application lists the granular dispatch parameter
details for the Real-Time and Advance Notice components of the program,
whereas the dispatch parameter table in Exhibit B of the Company's Application
reflects the maximum combined parameters. For example, the maximum dispatch
hours for the Real-Time and Advance Notice options in Table 6 are five hours and
60 hours respectively, so the combined maximum hours listed in Exhibit B is 65
hours. The Exhibit B flexible tarifftable is meant to provide the highJevel
maximum overview that can be updated as necessary through the flexible tariff
process. The Company's website will list the granular information which
customers will be able to access. This is similar to how the Company's other
demand-side management @SM) flexible tariffs operate.
With respect to the Marimum Events per year parameter, this detail was
inadvertently omitted from the table in Exhibit B. Table 6 lists the maximum
events for the Real-Time and Advance Notice options at 50 events and25 events
per year, respectively. The table below from Exhibit B has been updated to
incorporate the maximum events per year parameter, listing the total combined
maximum events at 75.
Recordholder:Shawn Grant
Loed Control
Program Dispatch Pcriod
Available
Disprtch
Hours
Maximum Dispetch
Hours / Events
(ocr Prosram Yerr)
Dispatch
Deys Dispatch Duration
Wattsmert
Batteries S-Yeer
Pilot
January I through
December 3l
l2:00am to
ll:59pm
Mountain Time
Not applicable
Monday
through
Sunday
Events may be held
multiple times perday
up to two full battery
dutv cvcles
Wattsmart
Business Demand
Resnonse
January I through
December 3l
l2:00am to
I l:59pm
Mountain Time
65 hours / 75 events
Monday
through
Sundav
Events will be limited to
four hours per day
Sponsor:Clay Monroe