20240223Staff 1-18 to PAC.pdf

ADAM TRIPLETT DEPUTY ATTORNEY GENERAL IDAHO PUBLIC UTILITIES COMMISSION PO BOX83720 BOISE, IDAHO 83720-0074 [phone]IDAHO BAR NO. 10221Street Address for Express Mail: 11331 W CHINDEN BLVD, BLDG 8, SUITE 201-A BOISE, ID 83714 Attorney for the Commission Staff I ' BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF ROCKY MOUNTAIN POWER'S APPLICATION FOR APPROVAL OF ADJUSTMENTS TO THE IRRIGATION
LOAD CONTROL PROGRAM
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)
) CASE NO. PAC-E-24-02 ) ) ) FIRST PRODUCTION
) REQUEST OF THE ) COMMISSION STAFF ) TO ROCKYMOUNTAIN ) POWER Staff of the Idaho Public Utilities Commission, by and through its attorney of record, Adam Triplett, Deputy Attorney General, requests that Rocky Mountain Power ("Company") provide the following documents and information as soon as possible, but no later than FRIDAY, MARCH 8, 2024.1This 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 1 Staff is requesting an expedited response. If responding by this date will be problematic, please call Staff's attorney at [phone]. FIRST PRODUCTION REQUEST TO ROCKY MOUNTAIN POWER 1 FEBRUARY 23, 2024
the person preparing the documents. Please also identify the name, job title, location, and
telephone number of the record holder.
In addition to the written copies provided as response to the requests, please provide all
Excel spreadsheets and electronic files with formulas intact and enabled.
REQUEST NO. 1: Please explain how the Company determined the appropriate
incentive amount for each incentive component detailed in Table No. 1 of the Application. (i.e.,
Base Incentive Rate, Bonus Incentive Rate, Mandatory Event Energy Reduction Payment
("ERP"), and Voluntary Event ERP). Please provide detailed workpapers supporting the
incentive amounts in excel format with equations intact and enabled.
a.Please clearly show how the program administration cost total accounts for the
expected participation in each incentive category, including voluntary events.
b.Please clearly show the expected mandatory event incentive payout and expected
voluntary event payout amounts relative to program benefits.
REQUEST NO. 2: On its current program webpage, the Company's compensation table
provides two Base Incentive Rates based on average expected kW per pump for pumps below or
above a 100 kw. In the proposed incentive structure, there is a single Base Incentive Rate based
on average expected kW per pump for each year of the program contract. Please answer the
following questions:
a.Please explain the rationale for the change from an incentive tiered by expected
pump size to a single incentive for each year of the offering.
b.Please explain the rationale for the change from a fixed incentive to an incentive
that changes over time.
c.Please describe any alternative incentive structures the Company considered and
why they were not selected for the program.
REQUEST NO. 3: On its current program webpage, the Company's compensation table
states that the bonus incentive rate is only applied if the program capacity is greater than 125
MW. In the proposed incentive structure, the Bonus Incentive Rate is applied only if a customer
participates in all mandatory events. Please answer the following questions:
a.Please explain the rationale for this change.
FIRST PRODUCTION REQUEST TO ROCKY MOUNTAIN POWER 2 FEBRUARY 23, 2024
b.Please describe any alternative incentive structures the Company considered and
why they were not selected for the program.
c.Please explain if the bonus incentive rate is incremental to the Base Incentive
Rate or if it replaces the Base Incentive Rate when the conditions are met.
REQUEST NO. 4: The Company's Application includes a Mandatory Event ERP Rate
that is not present in the Company's current offering. Please explain the rationale of the
additional incentive.
REQUEST NO. 5: On its current program webpage, the Company describes the
voluntary event dispatch window of June 1 to September 30. Please explain what voluntary
event dispatch parameters the Company is proposing for its updated program.
REQUEST NO. 6: In its Application, the Company details a Voluntary Event ERP of
$0.38/kWh. The Company's current program information provided by its website does not
include any similar rate. Please answer the following questions:
a.Please clarify if the current offering has an equivalent Voluntary Event ERP.
b.Please explain the rationale for this additional incentive.
REQUEST NO. 7: In its Application on page 5, the Company describes that the
Irrigation Load Control ("ILC") program can be dispatched in the event of system emergencies.
Please answer the following questions:
a.Please explain if and how participants will be paid for load reductions during
emergency events.
b.Please provide historical data for each emergency event in the past five years in
Excel format with equations enabled and intact. Whenever possible, please
include the following in the greatest level of detail available to the Company; (i.e.,
per event, per participant, per hour) event date, event duration, average available
load, realized load reduction, participant opt-outs, and incentive payouts.
REQUEST NO. 8: In its Application, the Company assumes 100% carryover of current
participants. Please explain if the Company has any forecasts of increased participation due to
the increased incentives.
FIRST PRODUCTION REQUEST TO ROCKY MOUNTAIN POWER 3 FEBRUARY 23, 2024
a.If so, please explain how the increase in incentive payments affects cost­
effectiveness.
b.If not, why not?
REQUEST NO. 9: Please explain how the Company arrived at the assumption that 80%
of enrolled capacity would qualify to receive bonus payments.
REQUEST NO. 10: Please provide historical data for each mandatory event in the past
five years in Excel format with equations enabled and intact. Whenever possible, please include
the following in the greatest level of detail available to the Company; (i.e., per event, per
participant, per hour) event date, event duration, average available load, realized load reduction,
participant opt-outs, and incentive pay outs.
REQUEST NO. 11: Please provide historical data for each voluntary event for the past
five years in Excel format with equations enabled and intact. Whenever possible, please include
the following in the greatest level of detail available to the Company; (i.e., per event, per
participant, per hour) event date, event duration, average available load, realized load reduction,
and incentive pay outs.
REQUEST NO. 12: Please describe what criteria the Company will monitor to inform
the need for adjustments to the ILC program.
REQUEST NO. 13: Please explain the time/season the Company expects to make
adjustments to the ILC program.
a.Please explain the components of the offering the Company expects it will
regularly update and at what frequency.
REQUEST NO. 14: Please explain the process the Company will use to make changes
to the ILC program.
a.Please explain how this process allows for and incorporates the input of the
Commission.
b.Please explain how the Company will communicate these changes with
participants.
FIRST PRODUCTION REQUEST TO ROCKY MOUNTAIN POWER 4 FEBRUARY 23, 2024
REQUEST NO. 15: The Company states that it intends to maintain the four-hour notification for 2024. Please answer the following: option. option. a.Please explain why it is necessary to maintain four-hour notification until the2025 program year.b.Please clarify if the Company will remove the four-hour notification after the2024 season.REQUEST NO. 16: Please provide a detailed description of the two-hour notification a.Please describe the rationale for introducing this option in the 2025 season.b.Please describe correspondence with customers that expresses a desire for thechange.c.Please describe the criteria the Company will use when considering customerparticipation in the two-hour notification option.d.Please describe the dispatch parameters, value structure, and incentive structurefor the two-hour notification option. Please note differences in these valuesbetween the real-time and four-hour notification options.e.Please explain how the Company intends to communicate this change withparticipating customers.f.Please explain the process the Company intends to use to submit this change tothe Commission for review.REQUEST NO. 17: Please provide a detailed description of the real-time scenario a.Please describe the rational for introducing this option in the 2025 season.b.Please describe correspondence with customers that expresses a desire for thechange.c.Please describe what criteria the Company will use when considering customerparticipation in the real-time option.FIRST PRODUCTION REQUEST TO ROCKY MOUNTAIN POWER 5 FEBRUARY 23, 2024
d.Please describe the dispatch parameters, value structure, and incentive structure
for the real-time option. Please note differences in these values between the four­
hour and two-hour notification options.
e.Please explain how the Company intends to communicate this change with
participating customers.
f.Please explain the process the Company intends to use to submit this change to
Commission for review.
REQUEST NO. 18: Please explain why the Company does not include ILC program in
its Tariff Schedules? Has the Company considered including this? If not, why not?
DATED at Boise, Idaho, this 23 day of February 2024. I:\Utility\UMISC\PRDREQIPAC-E-24-02 PR# 1 .docx FIRST PRODUCTION REQUEST TO ROCKY MOUNTAIN POWER 6
Adam Triplett Deputy Attorney General
FEBRUARY 23, 2024
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 23 DAY OF FEBRUARY 2024,
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO ROCKY MOUNTAIN POWER, IN CASE NO. PAC-E-
24-02, BY E-MAILING A COPY THEREOF, TO THE FOLLOWING:
MARK.ALDER
MICHAEL SNOW ROCKY MOUNTAIN POWER 1407 WEST NORTH TEMPLE STE 330 SALT LAKE CITY UT 84116 E-MAIL: [e-mail]
[e-mail]
DATA REQUEST RESPONSE CENTER E-MAIL ONLY:[e-mail]
ERIC L OLSEN
ECHO HA WK & OLSEN PLLC PO BOX6119 POCATELLO ID 83205 E-MAIL: [e-mail]
JOE DALLAS ROCKY MOUNTAIN POWER
825 NE MULTNOMAH ST STE 2000 PORTLAND OR 97232 E-MAIL: [e-mail]
LANCE KAUFMAN PhD 2623 NW BLUEBELL PLACE
CORY ALLIS OR 97330 E-MAIL: [e-mail]
SECRET
CERTIFICATE OF SERVICE