20230516_PACE2213_mdrk.pdf

DECISION MEMORANDUM - 1 - MAY 16, 2023
DECISION MEMORANDUM

TO: COMMISSIONER ANDERSON
COMMISSIONER HAMMOND
COMMISSIONER LODGE
COMMISSION SECRETARY
LEGAL

FROM: MICHAEL DUVAL
RICHARD KELLER

DATE: MAY 16, 2023

RE: IN THE MATTER OF ROCKY MOUNTAIN POWER’S APPLICATION
FOR AUTHORITY TO IMPLEMENT A COMMERCIAL AND
INDUSTRIAL DEMAND RESPONSE PROGRAM;
CASE NO. PAC-E-22-13.

BACKGROUND
On August 25, 2022, Rocky Mountain Power, a division of PacifiCorp (“Company”)
applied for authority to implement a Class 1 Commercial and Industrial Demand Response
(“CIDR”) program. The Company requested this program be implemented under the existing
Schedule 114 load management flexible tariff within the Demand Side Management (“DSM”)
portfolio.
On October 20, 2022, the Commission issued a Notice of Application, set an intervention
deadline, and suspended the proposed effective date until February 15, 2023. Order No. 35568.
On December 8, 2022, the Commission issued a Notice of Modified Procedure
establishing public comment and Company reply deadlines. Order No. 35616.
At the Commission’s January 3, 2023, Decision Meeting, Commission Staff (“Staff”)
conveyed to the Commission that, through discovery, the Company provided Staff new data—
specific to Idaho—which took Staff additional time to process. Staff recommended the
Commission (1) vacate the comment deadlines established in Order No. 35616 and issue new
comment deadlines; and (2) modify the suspension of proposed effective date. The Company
and intervenors supported modifying the deadlines.

DECISION MEMORANDUM - 2 - MAY 16, 2023
On January 11, 2023, the Commission issued Order No. 35662 amending the comment
deadlines and extended the effective date to April 1, 2023.
On March 31, 2023, the Commission issued Order No. 35724, approving the Company’s
Application with certain modifications. In its Order, the Commission directed the Company to
submit a compliance filing to include updates to the incentives offered, program equipment
costs, and dispatch parameters in Schedule 114.
On April 17, 2023, the Company submitted a compliance filing in response to Order No.
35724. Staff within its review identified modifications to Schedule 114 beyond those directed by
the Commission.
On May 5, 2023, the Commission issued Order No. 35772, rejecting the Company’s
earlier compliance filing. The order directed the Company to re-submit the compliance filing
which “strictly follows all imperatives and parameters outlined in Order No. 35724.”
On May 10, 2023, the Company re-submitted the compliance filing in response to Order
No(s). 35724 and 35772. This Memorandum addresses Staff’s review of the re-submitted filing.

STAFF REVIEW
Staff reviewed the Company’s compliance filing and revised tariff. Staff now believe that
the filing fully complies with Commission Order No. 35724.

STAFF RECOMMENDATION
Staff recommends the Commission approve Schedule 114 load management flexible
tariff submitted by the Company on May 10, 2023, as filed, with an effective date of April 1,
2023, consistent with Order No. 35724.

COMMISSION DECISION
Does the Commission wish to approve the compliance filing and tariff submitted by the
Company on May 10, 2023, as filed, with an effective date of April 1, 2023, consistent with
Order No. 35724?

____________________________
Michael Duval
Udmemos/PAC-E-22-13 Decision Memo