20240308PAC to Staff 1-18(Redacted).pdf

1407 W North Temple, Suite 330 Salt Lake City, Utah 84116
March 8, 2024 Monica Barrios-Sanchez Commission Secretary
Idaho Public Utilities Commission 11331 W. Chinden Blvd. Bldg. 8, Ste. 201-A Boise, ID 83714
[e-mail]
[e-mail] RE: ID PAC-E-24-02 IPUC Set 1 (1-18)
Please find enclosed Rocky Mountain Power’s Responses to IPUC 1st Set Data Requests 1-18.
Also provided is Attachment IPUC 10-1. Provided via BOX is Confidential Response IPUC 1 and Confidential Attachments IPUC 1 and 10-2. 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 the non-disclosure agreement (NDA) executed in this proceeding. If you have any questions, please feel free to call me at [phone]. Sincerely,

____/s/____ Mark Alder
Manager, Regulation
Enclosures
RECEIVED
Friday, March 8, 2024 2:45PM
IDAHO PUBLIC
UTILITIES COMMISSION
PAC-E-24-02 / Rocky Mountain Power March 8, 2024 IPUC Data Request 1
IPUC Data Request 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.
Confidential Response to IPUC Data Request 1
The Company proposed an initial Customer Base Rate incentive increase of 30
percent to account for the program incentive being stagnant over the prior contract terms. The exact value incorporated factors such as inflation, costs of living increases, cost effectiveness and the negative economic impacts of the COVID-19 pandemic compared to when the initial contract was executed. The Company also discussed this rate increase with the Idaho Irrigation Pumpers Association (IIPA)
and determined this was an appropriate increase for all parties involved.
The 2.5 percent yearly increase for the Base Incentive Rate and Bonus Incentive Rate was based on a review of inflation rates between 2014 and 2023 and
negotiations with the Program Administrator. According to data obtained from the
Bureau of Labor Statistics, inflation averaged 2.8 percent between 2014 and 2023, including particularly high rates in 2022 and 2023. The Company believes that an increase of 2.5 percent annually for Base Incentive Rate and Bonus Incentive Rate accurately reflects expected inflation rates as the past two years have skewed inflation amounts.

PAC-E-24-02 / Rocky Mountain Power March 8, 2024 IPUC Data Request 1
Figure 1 – US Inflation Rates (data.bls.gov)

During the previous contract period, Participating Customers were eligible for a bonus incentive up to 20 percent of their base incentive for any Participating Facility that participated in all Mandatory Program Events that lasted until 9 pm. With the new contract, Participating Customers are eligible to earn the Bonus Incentive Rate for any Participating Facility that participates in all Mandatory
Program Events in a given program year.
The Mandatory Energy Reduction Payment Rate (ERP) was not modified from the original contract value. It was determined that increasing the Base Incentive
Rate was sufficient to retain enrolled Participating Customers and encourage new
customer enrollment. Similar to the Base Incentive Rate increase rationale, the Voluntary ERP was doubled compared to the original contract value to account for inflation and to further encourage participants to participate in voluntary events.

(a) The Company has a pay-for-performance model with the Program Administrator. The Program Administration cost is a function of the total Base and Bonus Incentives earned by Participating Customers. The Program Administrator is only compensated based on capacity payment amounts issued
to the customer – ERPs are not included in the pay-for-performance model. Therefore, the Program Administrator is not compensated for Voluntary Program Events. Please refer to Confidential Attachment IPUC 1 which provides the cost
breakdown as well as the summarized confidential table provided below.
PAC-E-24-02 / Rocky Mountain Power March 8, 2024 IPUC Data Request 1
This breakdown assumes 80 percent of enrolled capacity receives the Bonus Incentive Rate. Anticipated Bonus Incentive, Base Incentive, and ERPs are modeled after 2022 invoicing adjusted to the new Program terms and assumptions.

Table 1 – Estimated Program Costs by Category1
2024 2028 2032
Participation
Total Program Administration Costs
Total Customer Incentives
Program Benefit Value

(b) Please refer to Confidential Attachment IPUC 1 and also to the confidential table provided in the Company’s response to subpart (a) above.

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 the non-disclosure agreement (NDA) executed in this proceeding.
Recordholder: Sierra Gentry Sponsor: Clay Monroe

1 Program costs assume 125 MW of enrolled capacity. Administration and incentive costs are variable based on program participation. Values have been rounded.
PAC-E-24-02 / Rocky Mountain Power March 8, 2024 IPUC Data Request 2
IPUC Data Request 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. Response to IPUC Data Request 2

(a) The Company believes that simplifying the incentive structure will reduce the ambiguity of how much a customer can earn if they are enrolling multiple pumps. The Company also believes simplifying the incentive structure will encourage customers to enroll smaller pumps, thus growing the program overall.
(b) In order for the program to remain attractive to Participating Customers over the
next 10-year period, incentives must at a minimum keep up with inflation. Rising costs of living and unstable job markets cause participating irrigators to pay workers higher wages year-over-year. By increasing the incentive by 2.5 percent
every year, irrigators are being more fairly compensated for their participation in
the program. (c) The Company considered a flat incentive rate that did not increase each season for both the Base Incentive Rate and the Bonus Incentive Rate. This was not selected because it did not fairly account for the changing operational costs faced by
Participating Customers enrolled in the program. While the program’s dispatching
is automatic, the irrigation load control program requires manual checks from the irrigators to verify the enrolled pumps are functioning properly after an event. The cost of this labor is expected to increase each season resulting from inflation and steadily rising costs of living, making a flat incentive rate not viable for continued program success. Recordholder: Sierra Gentry
Sponsor: Clay Monroe
PAC-E-24-02 / Rocky Mountain Power March 8, 2024 IPUC Data Request 3
IPUC Data Request 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.
(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.
Response to IPUC Data Request 3
(a) To clarify, the previous contract period had two distinctly separate bonus
incentives. The first bonus incentive was available to customers if the overall program capacity was greater than 125 megawatts (MW). The purpose of the 125 MW bonus incentive was meant to encourage Participating Customers to discuss the program with their colleagues and peers to enroll more capacity. However, enrolled capacity has not increased throughout the program’s life,
therefore the Company believes the 125 MW requirement no longer serves its
intended purpose and was removed for the next 10-year period. The second bonus incentive was available to Participating Facilities that
participated in all mandatory events that lasted through 9pm. This same bonus
incentive will remain available to Participating Customers for the next 10-year period but will be applicable for Participating Facilities that participate in all Mandatory Program Events regardless of when the events end. (b) The Company considered excluding a bonus incentive for the next 10-year
period, however, it was determined that including the bonus incentive serves
as an active encouragement for Participating Customers to participate in all scheduled mandatory events. A successful irrigation load control program requires consistent participation, and the bonus incentive helps promote this. The Company also considered providing another bonus incentive if the entire program enrollment was over a certain MW value, as was the case in prior years, however this bonus incentive was removed as it was determined to have a negligible effect on the program’s capacity.
PAC-E-24-02 / Rocky Mountain Power March 8, 2024 IPUC Data Request 3
(c) The Bonus Incentive Rate replaces the Base Incentive Rate when all conditions are met and is 20 percent higher than the Base Incentive Rate.
Recordholder: Sierra Gentry
Sponsor: Clay Monroe
PAC-E-24-02 / Rocky Mountain Power March 8, 2024 IPUC Data Request 4
IPUC Data Request 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.
Response to IPUC Data Request 4
The Mandatory Event Energy Reduction Payments (ERP) have not been posted
on the Company’s website but are present in the Company’s current offering. ERPs have been issued to customers in prior years to directly compensate them based on their actual load reduction during an event as opposed to just their available load reduction.

Recordholder: Sierra Gentry Sponsor: Clay Monroe
PAC-E-24-02 / Rocky Mountain Power March 8, 2024 IPUC Data Request 5
IPUC Data Request 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.
Response to IPUC Data Request 5
Voluntary events include any event scheduled outside of the Mandatory Event
parameters within the weeks including June 1 through September 30. No irrigation load control events will be called outside of the weeks including June 1 through September 30 under the current program design. Mandatory Event parameters were included in Table 2 of the Company’s Application in this proceeding.

Recordholder: Sierra Gentry
Sponsor: Clay Monroe
PAC-E-24-02 / Rocky Mountain Power March 8, 2024 IPUC Data Request 6
IPUC Data Request 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.
Response to IPUC Data Request 6 (a) The program through the 2023 season included a Voluntary Event Energy Reduction Payments (ERP), set at $0.19 per kilowatt-hour ($/kWh). As stated
in the Company’s response to IPUC Data Request 1, the Voluntary Event ERP
was doubled for the next 10-year period to account for inflation and to further encourage participants to participate in voluntary events.
(b) As discussed in the Company’s response to subpart (a) above, the Voluntary
Event ERP is not a new offering, and has been part of the program. The Voluntary Event ERP will continue to be provided as it has in the past, albeit with an increased incentive rate to account for inflation and to further encourage participants to participate in voluntary events.

Recordholder: Sierra Gentry Sponsor: Clay Monroe
PAC-E-24-02 / Rocky Mountain Power March 8, 2024 IPUC Data Request 7
IPUC Data Request 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.
Response to IPUC Data Request 7
(a) Emergency events will be treated as voluntary events from a Participating
Customer compensation perspective. Participating Customers will receive an event dispatch notification for emergency events, however, the notification time may be less than the defined minimum for that season as the need for an emergency event can arise with little to no notice.
(b) No emergency events have been called by the Idaho Irrigation Load Control
program in the past five years.
Recordholder: Sierra Gentry Sponsor: Clay Monroe
PAC-E-24-02 / Rocky Mountain Power March 8, 2024 IPUC Data Request 8
IPUC Data Request 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.
(a) If so, please explain how the increase in incentive payments affects cost-effectiveness.

(b) If not, why not? Response to IPUC Data Request 8 As discussed in the Company’s Application, the Idaho Irrigation Load Control
Program has seen a steady decline in enrollment over the program life. The rate of
decline has varied each year, making it difficult to forecast what a subsequent year may look like in terms of enrollment. While the Company did not create a forecast specifically for increased future enrollment based on increased
incentives, the Company believes the increased incentives will prevent further
participation decline and encourage irrigation customers who have previously unenrolled to rejoin. (a) The Company does not have any forecasts of increased participation due to the increased incentives. A cost effectiveness analysis can be created with an
increased enrollment estimate upon request.
(b) Please refer to the Company’s responses above.

Recordholder: Sierra Gentry Sponsor: Clay Monroe
PAC-E-24-02 / Rocky Mountain Power March 8, 2024 IPUC Data Request 9
IPUC Data Request 9 Please explain how the Company arrived at the assumption that 80% of enrolled capacity would qualify to receive bonus payments.
Response to IPUC Data Request 9 The Company assumed a higher percentage of enrolled capacity would qualify to
receive bonus payments as a conservative estimate to ensure the Idaho Irrigation
Load Control Program would remain cost effective in a scenario where the majority of participants qualified for bonus payments. Recordholder: Sierra Gentry

Sponsor: Clay Monroe
PAC-E-24-02 / Rocky Mountain Power March 8, 2024 IPUC Data Request 10
IPUC Data Request 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.
Response to IPUC Data Request 10
Data on mandatory and voluntary events has been filed with the Company’s annual reporting, all of which are available in Case No. PAC-E-05-10. For convenience, please refer to Attachment IPUC 10-1 which provides copies of the Demand Side Management (DSM) annual reports from 2018 to 2021, and
Confidential Attachment IPUC 10-2 which provides a copy of the 2022 DSM
annual report. Note: the 2023 DSM annual report will be filed with the Idaho Public Utilities Commission (IPUC) in Case No. PAC-E-05-10 by May 1, 2024.
The Company started tracking and reporting additional details and metrics for the
Irrigation Load Control Program beginning with the 2022 DSM annual report, specifically Confidential Appendix C (Irrigation Load Control Program Details). The level of detail provided in Confidential Appendix C is not available for program years 2018 through 2021. It is further worth noting that there were no dispatch events in 2019 for the Irrigation Load Control Program.

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 the non-disclosure agreement (NDA) executed in this proceeding.
Recordholder: Sierra Gentry Sponsor: Clay Monroe
PAC-E-24-02 / Rocky Mountain Power March 8, 2024 IPUC Data Request 11
IPUC Data Request 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.
Response to IPUC Data Request 11
Please refer to the Company’s response to IPUC Data Request 10. Recordholder: Sierra Gentry

Sponsor: Clay Monroe
PAC-E-24-02 / Rocky Mountain Power March 8, 2024 IPUC Data Request 12
IPUC Data Request 12 Please describe what criteria the Company will monitor to inform the need for adjustments to the ILC program.
Response to IPUC Data Request 12 The Company will monitor a variety of criteria that will inform the need for
program adjustments, including but not limited to the following:

• The number of customers enrolled,
• The number of pumps enrolled,
• The average size of enrolled pumps,
• The number of participating facilities eligible for the Bonus Incentive Rate,
• Weekly Available Load Reduction, and
• Annual survey results to document areas of support and areas of concern.
Recordholder: Sierra Gentry

Sponsor: Clay Monroe
PAC-E-24-02 / Rocky Mountain Power March 8, 2024 IPUC Data Request 13
IPUC Data Request 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.
Response to IPUC Data Request 13
The Company may make adjustments to the Idaho Irrigation Load Control Program whenever they become necessary throughout the year. However, the Company’s intent is to make any necessary adjustments to the program outside of the irrigation season (i.e. the weeks of June 1 through September 30), and after
discussing with Idaho Public Utilities Commission (IPUC) staff and irrigators.
(a) The Company does not anticipate making regular material updates to the Idaho Load Control Program for the foreseeable future. However, intermittent
changes may be necessary during the 10-year contract term, which may
include incentive adjustments, the minimum notification window for events, or other program design components. If changes become necessary, the Company would put forth a good faith effort to have changes become effective before the irrigation season begins for any given year, after discussing with IPUC staff and irrigators.

Recordholder: Sierra Gentry
Sponsor: Clay Monroe
PAC-E-24-02 / Rocky Mountain Power March 8, 2024 IPUC Data Request 14
IPUC Data Request 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. Response to IPUC Data Request 14 If material changes to the Idaho Irrigation Load Control Program are necessary,
the Company will use a process similar to the flexible tariff process the Company
uses for its demand side management (DSM) programs. (a) The flexible tariff process involves discussing proposed changes with Idaho
Public Utilities Commission (IPUC) staff and incorporating their feedback
prior to implementation. (b) The Company will discuss changes to the Idaho Load Control Program directly with the Idaho Irrigation Pumpers Association (IIPA) prior to implementation via conference calls or conventions, in addition to posting
notices on its website and issuing other direct communications to customers,
including email.
Recordholder: Michael Snow
Sponsor: Clay Monroe
PAC-E-24-02 / Rocky Mountain Power March 8, 2024 IPUC Data Request 15
IPUC Data Request 15 The Company states that it intends to maintain the four-hour notification for 2024. Please answer the following:

(a) Please explain why it is necessary to maintain four-hour notification until the 2025 program year.
(b) Please clarify if the Company will remove the four-hour notification after the
2024 season. Response to IPUC Data Request 15 (a) Reducing the event notification time by any amount will be a major change to
the Idaho Load Control Program and requires a discussion with irrigators to
determine if their operations are able to support such a change. The Company wishes to have direct conversations with participants to determine if such a change is feasible within the current structure of the program. There are
currently no definitive plans to reduce the notification time for the 2025
season either. Reducing the event notification time is a possible option that may be considered in the future.
(b) Please refer to the Company’s response to subpart (a) above. The Company does not currently plan to remove the four-hour notification after the 2024 season. Reducing the event notification is a possible option that may be
considered in the future.
Recordholder: Sierra Gentry Sponsor: Clay Monroe
PAC-E-24-02 / Rocky Mountain Power March 8, 2024 IPUC Data Request 16
IPUC Data Request 16 Please provide a detailed description of the two-hour notification option.
(a) Please describe the rationale for introducing this option in the 2025 season.
(b) Please describe correspondence with customers that expresses a desire for the change.

(c) Please describe the criteria the Company will use when considering customer participation in the two-hour notification option. (d) Please describe the dispatch parameters, value structure, and incentive structure for the two-hour notification option. Please note differences in these
values between the real-time and four-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 the Commission for review. Response to IPUC Data Request 16
When a demand response event is dispatched, the program administrator will send
a dispatch notification to participants alerting them of the upcoming event. The notification will include the event start time, the event end time, and the event date. Currently, a notification is sent to the participant at least four hours prior to
the event start time. As discussed in the Company’s response to IPUC Data
Request 15, reducing the current four-hour notification window is a possible option that may be considered in the future. (a) The Company is not definitively introducing this option in the 2025 season but may consider it as a possible option after discussing with irrigators and
Idaho Public Utilities Commission (IPUC) staff.

(b) The Company has met with the Idaho Irrigation Pumpers Association (IIPA) to discuss the Idaho Load Control Program over the past several years. During these discussions, the Company has explained how demand response programs are transitioning to more real-time dispatches, and the potential benefits that come from operating a fast-acting resource. As stated in the Company’s response to subpart (a) above, the Company is not definitively introducing a reduced notification window for the program. If this option is considered in the future for the program, it will be discussed with customers
PAC-E-24-02 / Rocky Mountain Power March 8, 2024 IPUC Data Request 16
prior to implementation to ensure that it is feasible within the current structure of the program. (c) The Company will consider how the reduced notification time may impact
irrigation operations. The Company will discuss any proposed operational
changes with the IIPA and may issue a survey addressing such a program change to all program participants.
(d) The Company has not determined if an additional incentive structure is
required for two-hour notifications at this time. The Company may examine alternative incentives for a reduced notification window if the reduced notification option is considered. If a reduce notification option is considered, details will be discussed with IPUC staff and customers prior to implementation.

(e) The Company will discuss changes to the Idaho Load Control Program directly with the irrigators prior to implementation via conference calls or conventions, in addition to posting notices on its website and issuing other
direct communications to customers, including email.
(f) If material changes to the Idaho Load Control Program are necessary, the Company will use a process similar to the flexible tariff process the Company uses for its demand-side management (DSM) programs, which involves discussing proposed changes with IPUC staff and incorporating their feedback
prior to implementation.
Recordholder: Sierra Gentry

Sponsor: Clay Monroe
PAC-E-24-02 / Rocky Mountain Power March 8, 2024 IPUC Data Request 17
IPUC Data Request 17 Please provide a detailed description of the real-time scenario option.
(a) Please describe the rational for introducing this option in the 2025 season.
(b) Please describe correspondence with customers that expresses a desire for the change.

(c) Please describe what criteria the Company will use when considering customer participation in the real-time option. (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. Response to IPUC Data Request 17
Real-time event scenarios have not been prepared at this time. The Company
negotiated the possible option of a real-time resource in the new 10-year contract for the program, should the need arise. Similar to the option for a two-hour notification window, the Company does not have a definitive date or intent to
implement a real-time resource at this time. If a real-time resource is needed in
the future, the Company will discuss details for this option with Idaho Public Utilities Commission (IPUC) staff and irrigators prior to implementation. (a) The Company is not definitively introducing this option in the 2025 season but may consider it as a possible option after discussing with irrigators and
IPUC staff.

(b) Please refer to the Company’s response to IPUC Data Request 16 subpart (b). The Company is not definitively introducing a real-time scenario for the program. If this option is considered in the future for the program, it will be discussed with customers prior to implementation to ensure that it is feasible within the current structure of the program.
PAC-E-24-02 / Rocky Mountain Power March 8, 2024 IPUC Data Request 17
(c) The Company will consider how a real-time option may impact irrigation operations. The Company will discuss any proposed operational changes with the Idaho Irrigation Pumpers Association (IIPA) and may issue a survey addressing such a program change to all program participants.

(d) The Company has not determined if an additional incentive structure is
required for a real-time option at this time. The Company may examine alternative incentives for a real-time scenario if this option is considered. If a real-time option is considered, details will be discussed with IPUC staff and customers prior to implementation.
(e) The Company will discuss changes to the Idaho Load Control Program directly with the irrigators prior to implementation via conference calls or conventions, in addition to posting notices on its website and issuing other direct communications to customers, including email.

(f) If material changes to the Idaho Load Control Program are necessary, the Company will use a process similar to the flexible tariff process the Company uses for its demand side management (DSM) programs, which involves discussing proposed changes with IPUC staff and incorporating their feedback prior to implementation. Recordholder: Sierra Gentry
Sponsor: Clay Monroe
PAC-E-24-02 / Rocky Mountain Power March 8, 2024 IPUC Data Request 18
IPUC Data Request 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?
Response to IPUC Data Request 18 When the Irrigation Load Control Program was filed under the previous contract
in Case No. PAC-E-12-14, it was approved without a tariff schedule. Because the
previous approval excluded a tariff schedule, the Company filed the new contract for the Idaho Load Control Program in a similar vein. However, the Company is not opposed to having a tariff schedule for the Idaho Load Control Program if that is something the Idaho Public Utilities Commission (IPUC) prefers. If a tariff schedule is preferable, the Company would advocate for creating a new flexible
tariff for the Idaho Load Control Program or adding the Idaho Load Control
Program to the Company’s existing Schedule 114 flexible tariff for load management programs. If a flexible tariff was created for the Idaho Load Control Program, any changes to the program would follow the same flexible tariff
process as the Company’s existing demand-side management (DSM) programs.
Recordholder: Michael Snow Sponsor: Clay Monroe