20230124PAC to Bayer 1-12.pdf

1407 W North Temple, Suite 330 Salt Lake City, Utah 84116
January 23, 2023
Thomas J. Budge, ISB No. 7465 RACINE OLSON, PLLP
P.O. Box 1391; 201 E. Center Pocatello, Idaho 83204-1391 [e-mail] (C)
RE: ID PAC-E-22-13 Bayer Set 1 (1-12)
Please find enclosed Rocky Mountain Power’s Responses to Bayer 1st Set Data Requests 1-12. The remaining responses will be provided separately. Also provided are Attachments Bayer 1, 2-1, and 9. The Confidential Attachments Bayer 2-2 and 3 are provided via BOX. Confidentialinformation is provided subject to protection under IDAPA 31.01.01.067 and 31.01.01.233, theIdaho 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,
____/s/____ Mark Alder
Manager, Regulation
Enclosures C.c.: Jan Noriyuki/IPUC [e-mail] (C)
Eric L. Olsen/IIPA [e-mail] Lance Kaufman/IIPA [e-mail] Brian C. Collins/Bayer [e-mail] (C) Greg Meyer/Bayer [e-mail] (C)
RECEIVED
Monday, January 23, 2023 3:06:01 PM
IDAHO PUBLIC
UTILITIES COMMISSION
PAC-E-22-13 / Rocky Mountain Power January 23, 2023 Bayer Data Request 1
Bayer Data Request 1 Please provide a copy of all production requests received from Commission Staff and other parties.
Response to Bayer Data Request 1 As an intervenor in this proceeding, and pursuant to Idaho Public Utilities
Commission (IPUC) rules, all parties are required to serve their production
requests / data requests on all parties who have intervened in a proceeding. Therefore, pursuant to IPUC rules, Bayer should be copied on all requests by the requesting intervenor / party. Notwithstanding the foregoing statement, the Company responds as follows:
Please refer to Attachment Bayer 1 which provides a copy of the first set of data
requests received from IPUC staff, which were submitted to the Company before Bayer petitioned to intervene in this proceeding.

Recordholder: Not Applicable Sponsor: Not Applicable
PAC-E-22-13 / Rocky Mountain Power January 23, 2023 Bayer Data Request 2
Bayer Data Request 2 Please provide a copy of your responses to production requests received from Commission Staff and other parties.
Response to Bayer Data Request 2 Please refer to Attachment Bayer 2-1 and Confidential Attachment Bayer 2-2.

Going forward, Bayer Corporation (Bayer) will be copied on all outgoing responses. 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, and further subject
to any subsequent Non-Disclosure Agreement (NDA) executed in this proceeding.

Recordholder: Not Applicable Sponsor: Not Applicable
PAC-E-22-13 / Rocky Mountain Power January 23, 2023 Bayer Data Request 3
Bayer Data Request 3 Please provide a copy of the work papers supporting the Application filed in this matter. To the extent that the work papers include any spreadsheets or models,
please provide in executable native format with all formulas intact. Response to Bayer Data Request 3
Please refer to the work papers included with the Company’s response to Bayer
Request Data Request 2, specifically the Company’s responses to IPUC Data Request 16 and IPUC Data Request 26. Also, please refer to Confidential Attachment Bayer 3 which provides a copy of Confidential Exhibit C which was included with the Company’s Application.
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, and further subject to any subsequent Non-Disclosure Agreement (NDA) executed in this proceeding.

Recordholder: Not Applicable Sponsor: Not Applicable
PAC-E-22-13 / Rocky Mountain Power January 23, 2023 Bayer Data Request 4
Bayer Data Request 4 Please state the number of Company customers in Idaho with a load greater than 500 kW.
Response to Bayer Data Request 4 In Idaho, the Company has 36 customer locations with a load of 500 kilowatts
(kW) or greater, and 28 customers that exceed 500 kW of aggregate load across
all their Idaho locations. Recordholder: Shawn Grant
Sponsor: Clay Monroe

PAC-E-22-13 / Rocky Mountain Power January 23, 2023 Bayer Data Request 5
Bayer Data Request 5 Please state the number of Company customers in Idaho that the Company anticipates may participate in the Wattsmart Business Demand Response Program
(the “Program”), and state the collective load such customers. Response to Bayer Data Request 5
Please refer to Table 5 of the Company’s Application. By 2027, the Company
estimates that 15 customers will be participating in the program, providing 15 megawatts (MW) of curtailable load for an average of 1 MW per customer. Recordholder: Shawn Grant

Sponsor: Clay Monroe
PAC-E-22-13 / Rocky Mountain Power January 23, 2023 Bayer Data Request 6
Bayer Data Request 6 Please explain why the Company proposes that the Program be treated as a situs program as opposed to a system program.
Response to Bayer Data Request 6 The Company discussed the topic of situs-assigned versus system-assigned
resources / programs with Idaho Public Utilities Commission (IPUC) staff
before the Company’s Application for a battery demand response (DR) program was filed in July 2021. Discussions with IPUC staff concluded that new DR programs should be proposed as situs-assigned until the topic could be discussed and considered in the Multi-State Process (MSP) forum and incorporated into a future Multi-State Process protocol framework.

Recordholder: Shawn Grant
Sponsor: Clay Monroe

PAC-E-22-13 / Rocky Mountain Power January 23, 2023 Bayer Data Request 7
Bayer Data Request 7 Please state the anticipated effect on rates charged to each customer class in Idaho if the Program achieves 15 MW of curtailable demand response.
Response to Bayer Data Request 7 If the Company’s program is approved, it is anticipated that all rates on Schedule
191 will need to be increased to account for the program’s budget based on
previous forecasts. Upon program approval, the Company will conduct a new rate analysis and subsequently submit a new application with the Idaho Public Utilities Commission (IPUC) requesting approval to adjust the Schedule 191 rates based on the new rate analysis.

Recordholder: Shawn Grant Sponsor: Clay Monroe

PAC-E-22-13 / Rocky Mountain Power January 23, 2023 Bayer Data Request 8
Bayer Data Request 8 If the Program offered by the Company in Idaho generated more interest than 15 MW, would the Company expand the program demand response limit beyond 15
MW? Response to Bayer Data Request 8
If there is enough customer participation and interest to generate more than 15
megawatts (MW), and if the program remains cost effective, the Company may consider expanding the program beyond the initial 15 MW forecast. Recordholder: Shawn Grant

Sponsor: Clay Monroe

PAC-E-22-13 / Rocky Mountain Power January 23, 2023 Bayer Data Request 9
Bayer Data Request 9 Please identify by name and case number all applications filed by the Company in other jurisdictions for similar commercial and industrial demand response
programs to the Program. For those jurisdictions that have an approved program
similar to the Program, please provide the tariffs authorizing that program. Response to Bayer Data Request 9

In Utah, the Company submitted a filing on June 6, 2022 with the Public Service Commission of Utah (UPSC) in Docket No. 22-035-T09, requesting approval of a new commercial and industrial demand response (C&I DR) program. Utah’s program, Schedule 114 (Load Management Program), was approved effective July 6, 2022.

In Washington, the Company submitted a filing on November 16, 2022 with the Washington Utilities and Transportation Commission (WUTC) in Docket No. UE-220848, requesting approval of a new C&I DR program. Washington’s
program, Schedule 106 (Demand Response Programs), is anticipated to receive
approval in January 2023. In Oregon, the Company submitted a filing on October 14, 2022 with the Public Utility Commission of Oregon (OPUC) in Docket No. ADV 1436, requesting approval of a new C&I DR program. Oregon’s program, Schedule 106 (Demand
Response Programs), was approved effective November 16, 2022.
Please refer to Attachment Bayer 9 which provides copies of the above referenced Utah, Washington and Oregon schedules.

Recordholder: Michael Snow Sponsor: Clay Monroe

PAC-E-22-13 / Rocky Mountain Power January 23, 2023 Bayer Data Request 10
Bayer Data Request 10 If the Company anticipates filing an application in one or more other states for a commercial and industrial program similar to the Program, please identify which
states in which the Company anticipates filing such application and the
anticipated filing date. Please provide a detailed discussion of the Program parameters.
Response to Bayer Data Request 10
The Company anticipates filing an application in Q1 2023 with the Wyoming Public Service Commission (WPSC) that will include, among other things, a request for approval of a new commercial and industrial demand response (C&I DR) program. The proposed program parameters for Wyoming’s program are
anticipated to be similar to the program parameters filed in Idaho, which have
been provided in the Company’s Application and in the Company’s responses to data requests already submitted in this proceeding to date.

Recordholder: Michael Snow Sponsor: Clay Monroe

PAC-E-22-13 / Rocky Mountain Power January 23, 2023 Bayer Data Request 11
Bayer Data Request 11 Does the Company anticipate that the Wattsmart Program and/or other programs proposed by the Company will replace the current interruptible products included
in the Bayer special contract? Response to Bayer Data Request 11
The Company assumes that the reference to “Wattsmart Program” is intended to
be a reference to the Wattsmart Business Demand Response program, and that the reference to “other programs” is intended to be a reference to other and / or similar demand response programs. Based on the foregoing assumption, the Company responds as follows:
No.
Recordholder: Irene Heng

Sponsor: Craig Eller
PAC-E-22-13 / Rocky Mountain Power January 23, 2023 Bayer Data Request 12
Bayer Data Request 12 Does the Company anticipate that similar programs offered in other states may impact the special contracts of other customers?
Response to Bayer Data Request 12 The Company assumes that the reference to “similar programs” is intended to be a
reference to similar demand response programs as proposed in the Company’s
Application for the Wattsmart Business Demand Response program. Based on the foregoing assumption, the Company responds as follows: No.

Recordholder: Irene Heng Sponsor: Craig Eller