20230124Attachment 1 to Bayer.pdf

MICHAEL DUVAL ElVEÜ
DEPUTY ATTORNEY GENERAL p :()\IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720 --3-oSIONBOISE,IDAHO 83720-0074
[phone]
IDAHO BAR NO.11714
Street Address for Express Mail:
11331 W CHINDEN BLVD,BLDG 8,SUITE 201-A
BOISE,ID 83714
Attorneyfor the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION )OF ROCKY MOUNTAIN POWER FOR )CASE NO.PAC-E-22-13
AUTHORITY TO IMPLEMENT A )COMMERCIAL AI\D INDUSTRIAL DEMAI\D )RESPONSE PROGRAM )FIRST PRODUCTION
)REQUESTOF 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 followingdocuments 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 supplementaryresponses,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 telephonenumber of
the person preparing the documents.Please also identify the name,job title,location,and
telephone number of the record holder.
FIRST PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 1 OCTOBER l1,2022
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.
REQUESTNO.1:Please explain and quantifyhow the commercial and industrial
demand response program will directly benefit customers of Rocky Mountain Power in Idaho
that are not part of the program.
REQUESTNO.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.
REQUESTNO.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.
REQUESTNO.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.
REQUESTNO.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.
REQUESTNO.6:Please explain the rational for the lower initial offered incentive
amount of $175/kW if the customer is able to participate in both the Real Time and Advance
Notice Option.Application at 5.
REQUESTNO.7:Please explain and quantifythe 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 PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 2 OCTOBER 11,2022
REQUESTNO.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.
REQUESTNO.9:Please explain why the Wattsmart Business Demand Response
Program should be managed through a flexible tariff process.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.
REQUESTNO.10:Please provide the website link to the program incentives
referenced within the tariff.
REQUESTNO.11:Please provide a listing of all current PacifiCorp Demand Response
programs.The listing should identify each of the followingitems below:
a.Jurisdiction/State
b.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)
f.Program Dispatch Period
g.Dispatch Days
h.Available Dispatch Hours
i.Maximum Dispatch Hours
j.Maximum Dispatch Events
k.Dispatch Duration
1.Dispatch Notification
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
FIRST PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 3 OCTOBER l1,2022
r.Average Realized Load MW (at Generator)for 2021
s.Maximum Realized Load MW (at Generator)for 2021
REQUESTNO.12:Please explain how each of the followingprogram parameters were
determined.In the explanation please include:(1)the rationale used (basis);(2)the workpapers
of the calculations (or by using an example where appropriate);(3)the specific source of
informationfor 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.
REQUESTNO.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?
REQUESTNO.14:How can the incentive structure be modified to account for the time
value of capacity?
REQUESTNO.15:Why are the combined advanced notice and real time participants
priced higher than real time only participants?
REQUESTNO.16:For the Company's cost-effectiveness calculation provided in
Exhibit C,please provide the followingin Excel format with all formulas enabled:
FIRST PRODUCTIONREQUEST
TO ROCKY MOUNTAIN POWER 4 OCTOBER 11,2022
a.Please provide all workpapers for the cost effectiveness study shown in Exhibit C
includingall 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.
REQUESTNO.17:How frequently(i.e.,annually,quarterly,as needed,etc.)does the
Company expect to consider program changes?
REQUESTNO.18:What criteria will the Company use to evaluate program changes?
REQUESTNO.19:Please provide estimates for the cost range,inventoryrequirements,
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.
REQUESTNO.20:Please provide the reasoning for the proposed dispatch period and
available dispatch hours.
REQUESTNO.21:Please explain if there any operational,differing processes,or other
differences between Demand Response programs and Energy Efficiencymeasures for the
flexible tariff process.
REQUESTNO.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 |Í day of October 2022.
Michael Duval
Deputy AttorneyGeneral
i:umise:prodreq/pace22.13mdrk prod req l
FIRST PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 6 OCTOBER 11,2022
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 11TH DAY OF OCTOBER 2022,SERVED THE FOREGOING FIRST PRODUCTION REQUESTOF THECOMMISSIONSTAFFTOROCKYMOUNTAINPOWER,IN CASE NO.PAC-E-22-13,BY E-MAILING A COPY THEREOF,TO THE FOLLOWING:
TED WESTON MICHAEL S SNOWROCKYMOUNTAINPOWERROCKYMOUNTAIN POWER1407WESTNORTHTEMPLESTE3301407WNTEMPLESTE320SALTLAKECITYUT84116SALTLAKECITYUT84116E-MAIL:[e-mail] E-MAIL:[e-mail]
DATA REQUEST RESPONSE CENTER
E-MAIL ONLY:
datarequest a pacificorp.com
SECRE ARY
CERTIFICATE OF SERVICE