20210715Application.pdf

Y ROCKY MOUNTAIN
POWER
ADIVISION OF PACIH@RP
Ii r r. ':1,;--i-.--lt -J
;..:, ,;i.i- l5 Pi{ lr: 3l 1407 W. North Temple, Suite 330
Saft Lake City, Utah 84116
July 15,2021 :1{
iji
VA ELECTRONIC DELIVERY
Jan Noriyuki
Commission Secretary
Idaho Public Utilities Commission
ll33l W. Chinden Blvd
Building 8 Suite 20lA
Boise,lD 83714
Re: CASE NO. PAC-E-21-16
IN THE MATTER OX'THE APPLICATION OF ROCKY MOT]NTAIN POWER
FOR AUTHORITY TO IMPLEMENT A BATTERY DEMAND RESPONSE
PROGRAM
Dear Ms. Noriyuki:
Please find for filing Rocky Mountain Power's Application in the above-referenced matter.
Informal inquiries may be directed to Ted Weston, Idaho Regulatory Manager at [phone]
or Michael Snow, Customer Innovation Regulatory Manager at [phone].
truly yours,
Joelle R. Steward
Vice-President of Regulation
Enclosures
"^..D
Emily Wegener, ISB# I 1614
Rocky Mountain Power
1407 West North Temple, Suite 320
salt Lake city, utah 841l6
Telephone : [phone]
Email: [e-mail]
Attorneyfor Roclcy Mountain Power
BEFORE TIIE IDAHO PUBLIC UTILITIES COMMISSION
IN TITE MATTER OF TIIE APPLICATION
OF ROCKY MOT'NTAIN POWER FOR
AUTHORITY TO IMPLEMENT A
BATTERY DEMAND RESPONSE
PROGRAM
CASE NO. PAC.EAI-rc
APPLICATION
Rocky Mountain Power, a division of PacifiCorp (the 'oCompany"), hereby petitions
the Idaho Public Utilities Commission (the "Commission") for authority to implement a
Class I battery demand response program ("Wattsmart Baffery" or "Program") under a new
Schedule I 14 load management tariffwithin the demand side management ("DSM") portfolio.
In support of this Application, Rocky Mountain Power states:
l. Rocky Mountain Power is authorized to do business in the state of Idaho as a
public utility providing retail electric service to approximately 86,500 customers. Rocky
Mountain Power is a public utility subject to the jurisdiction of the Commission pursuant to
Idaho Code $ 6l-129.
2. This Application is filed pursuant to Idaho Code $$ 61-301, 6l-307,61-622,
and 6l-623. In particular, Idaho Code $ 6l-623 empowers the Commission to determine the
propriety of proposed rate schedules, $$ 61-307 and 6l-622 require Commission approval
)
)
)
)
)
APPLICATION OF
ROCKY MOUNTAIN POWER
Page I
prior to any change in rates, and $ 61-301 requires Idaho retail electric rates to be just and
reasonable.
3. The Company seeks a flexible tariff, as permitted by the Commission in earlier
dockets, which will allow the company to "adjust Program details without advance
Commission approval if the Company informally obtains Staff input and resolves any Staff
concerns before implementing the change."l A flexible tariff will allow the Company to
manage and publish Program details on the Company's website, with hard copies provided to
customers upon request, while allowing for adequate Staff input. Before the Company makes
Program changes, it will provide Staff with its intended modifications and allow suffrcient time
to resolve any Staff concerns. After Staff s concerns are resolved, the Company will post the
final set ofchanges for at least 45 days before the changes are to take effect.
BACKGROI]ND
4. The Company has offered a variety of demand side management ("DSM")
programs to its customers since the 1970s. DSM programs offered by Rocky Mountain Power
are designed with the goal to be cost-effective. On March 2,2006, the Commission approved
cost recovery of DSM programs through Schedule 191 applied to customers' bills effective
May 1,2006. Schedule 191 allows Idaho customers to participate in cost-effective DSM
programs while providing the Company the ability to recover the costs of providing these
programs.
I In the Matter of PocifiCorp DBA RoclE Mountain Power's Application to Revise Electric Serttice Schedule
I l5 Finanswer Express, Case No. PAC-E-12-10, Order No. 32594 at 5 (July 13,2012). The Company's flexible
tariff process is described in detail in the testimony accompanying the Company's application in Case No.
PAC-E-12-10, Direct Testimony of Nancy M. Goddard at 16-18 and Attachment C thereto.
APPLICATION OF
ROCKY MOUNTAIN POWER
Page2
PROGRAM OVERVIEW
5. The WattsmartBattery Program will promote and incentivize the installation of
individual batteries for system-wide integration which will facilitate grid management. The
Company's 20l9Integrated Resource Plan includes nearly 600 megawatts ("MW") of battery
storage capacity by 2024. Establishing Wattsmart Battery will ensure that battery equipment
installed by customers behind the meter is integrated safely into the Company's systems and
will provide benefits for both the customer and the grid. Leveraging the batteries from the
Wattsmart Battery Program will create opportunity in the following ileas:
Utility Grid Management - The Wattsmart Battery Program will enable the Company
to utilize qualified batteries for utility grid management 24 hours per dayl365 days per
year, providing year-round value to effectively manage the electric grid. The batteries
may be utilized for traditional demand response, frequency reserve, contingency
reserve, regulation reseryes, regional grid management, backup power and other
ancillary benefits in addition to reducing peak load on the electric system. Initial
parameters used to dispatch the batteries for grid management are identified in the
Dispatch Period section below. As the Program matures, dispatch parameters may
change for continual improvement. Initially, batteries will be used to off-set customers'
load, but as the Program evolves and matures, the Company intends to add other
capabilities, such as allowing customers to charge batteries during the day with excess
solar and export the solar energy during peak times, in order to maximize benefits for
all parties.
Load Shaping - The Company will help customers optimize batteries in coordination
with daily peak and off-peak periods. For example, a customer with solar will charge
the battery with any excess generation during the middle of the day, and in turn will
utilize the battery to offset energy use during peak periods. Partnering with customers
with batteries to manage excess solar during the day and peak periods in the evenings
will provide the greatest benefits for customers and the utility grid.
a
o
a
APPLICATION OF
ROCKY MOUNTAIN POWER
Utility Integration of Behind-the-Meter Batteries - The battery storage industry is
still in its infancy, and there is a lack of standards for utility grid integration from both
Page 3
a safety and operational perspective. This program will help provide battery
manufacturers guidance on how to quali$ to participate in a utility grid optimized
battery solution.
CUSTOMER PARTICIPATION AND ELIGIBILITY
6. The Wattsmart Battery Program will be available to all retail tariff customers
taking service under the Company's electric service schedules listed on Schedule l9l -
Customer Efficiency Services Rate Adjustment. Both residential and commercial customers
may participate; however, the Company anticipates that initially, participation will come from
residential customers with solar.
7. Customers may participate by installing eligible battery equipment and
allowing the Company to utilize the battery for grid management. Customers will be
compensated for enrolling through an effollment incentive and an annual bill credit. Customers
will be required to commit to the Program for a minimum of four (4) years to receive an
enrollment incentive. After the commitment term, customers will have the opportunity to
receive an annual incentive for their continued participation beyond the initial commitment
term. The commitment term may change depending on Program needs.
8. Participating customers will also be required to provide information including
their name, business (if applicable), installation address, and contact information to assist with
eligibility and installation verihcation activities prior to enrolling. If a participating customer
chooses to end their participation during their initial commitment period, the Company may
require the participating customer to retum their enrollment incentive on a pro-rated basis.
9. Batteries must meet program participation requirements to qualiff for an
incentive, including the integration into the Company's Distributed Battery Grid Management
APPLICATION OF
ROCKY MOI.]NTAIN POWER
Page 4
Solution ("DBGMS"). Battery manufacturers who have a product capable of meeting the
requirements for utility-controlled demand response and who are willing to work with the
Company and its partners to integrate into the DBGMS can quali$ their batteries for
participation in the Wattsmart Battery Program.
INCENTIVE STRUCTURE
10. Wattsmart Battery incentives will be available to customers with installed
batteries capable of communicating with the Company's DBGMS. An up-front enrollment
payment incentive will be offered to customers who commit to the minimum term with a newly
purchased battery. The minimum term will initially be set at four years but may change as the
Program evolves. Program participants will also receive an annual bill credit incentive for their
continued to participation.
1 1. Customers with pre-existing eligible batteries may also participate in the
Program but will not be required to commit to a minimum term. Instead, due to free ridership
concems, customers with existing eligible batteries may start off at the increased annual bill
credit incentive for as long as they remain enrolled.
12. Customers will receive their enrollment incentive as a direct payment once
eligibility and installation have been verified. Annual participation incentives will be given as
monthly bill credits. Table I provides the maximum incentive levels for Program enrollment
and annual participation incentives.
13. Initially, residential incentives will be split bet'ween customers with and without
existing solar. The incentive for customers with solar installed prior to September 2021will be
the maximum amount of $I50/kilowatt ("kW") multiplied by the commitment term. The
APPLICATION OF
ROCKY MOUNTAIN POWER
Page 5
offered incentive for customers with solar installed after August 2021 will be set at $100/kW
multiplied by the commitment term.
Table I - Wattsmart Batterv Incentives
14. Enrollment incentives will be based on the kW capacity of the enrolled battery,
multiplied by the commitment term. For example, if a residential customer enrolls a 5kW
battery with a commitment term of 4 years, their enrollment incentive will be $3,000 (5kW x
$150 x 4 years). During the commitment period for years 2to 4, the program participation
annual incentive would be $75 (5kW x $15). If the same customer continues to participate
beyond the 4-year commitment term, their annual participation incentive could be up to $250
(5kW x $50). If a customer opts out of participating after their commitment term, their annual
participation incentive will be pro-rated.
15. At the Company's discretion, custom incentives and commitment terms may be
considered for customers with custom battery projects or large capacity batteries. The
Company will evaluate incentive levels and program requirements periodically and may adjust
2 Enrollment Incentives will be capped at70o/o of battery equipment costs and available for new battery purchases
only.
3 Participation Incentives are eligible to be applied towards monthly energy charges. Customers will still be
responsible for fixed customer charges.
a Applicable to new batteries after the commitment term or existing batteries where the enrollment incentive and
commitment term is not applicable. Participation lncentives are eligible to be applied towards monthly energy
charges. Customers will still be responsible for fixed customer charges.
APPLICATION OF
ROCKY MOI.INTAIN POWER
Load
Management
Program
Participating
Equipment
Maximum Incentive "uD tott
Enrollment
Incentive2
Annual Participation
Incentive During
Commitment Terms
Annual
Participation
Incentivea
Wattsmart
Battery
Residential
Batteries
$150/kW x Annual
Commitment Term $ls/kw $50/kw
Commercial
Batteries
$150/kW x Annual
Commitment Term $lslkw $so/kw
Custom Custom
Page 6
them through the appropriate process based upon various factors, such as battery market
changes, federal and state incentive levels, participation numbers and cost effectiveness.
16. As an altemative solution for customers who want batteries, but do not have the
funds to cover the associated equipment and installation costs, the Company may provide a
lease type agreement option, where the Company will work with qualified trade-allies to install
and maintain the batteries.
PROJECTED PARTICIPATION AI\D COSTS
L7. The Wattsmart Battery Program is forecast to achieve approximately l0 MW
of battery demand response by 2029. The majority of expenditures in the initial years of the
program are anticipated to be customer enrollment incentives. Table 2 provides a breakdown
of estimated program costs by category for 2022 through 2024. Table 3 provides a 6-year
outlook of proj ected participation.
Table 2 - Estimated Proeram Costs bv Cateeorv
Cost Catesory 2022 2023 2024
Program Administration $5.000 $10.000 $10.000
Software Costs $5,000 $15,000 $31,000
Marketins $s.000 $s.000 $s.000
Total Incentives $300,000 $600.000 $960.000
Total Proqram Costs $315,000 $630,000 $1,006,000
Table 3 - Estimated 6-Year Proeram Particioation
APPLICATION OF
ROCKY MOUNTAIN POWER
Year Estimated Battery
Participation
Estimated kW -
Cumulative
2022 100 500
2023 200 1.500
2024 300 3.000
2025 400 5.000
2026 475 7.375
2027 475 9.750
PageT
QUALITY ASSURANCE AND ELIGIBLE EQUIPMENT
18. In order for the Company to communicate with installed battery equipment,
participating customers must have a reliable internet connection and Wi-Fi network and any
other related equipment or system elements on the premises that may be required by the
Company or equipment manufacturer. Battery manufacturers will be eligible to participate in
the Program as long as they are willing to allow their batteries to be integrated into the
Company's DBGMS and meet equipment eligibility. In order to justiff the incentives being
provided and to maintain cost effectiveness, the batteries must be able to provide daily load
cycling, frequency response, and parameters identified below.
19. At the outset of the Wattsmart Battery program, eligible equipment may consist
of the following:
o Ability to integrate in the DBGMS
o Utility grade batteries with a minimum of 4 kW / l0 kwh
o Minimum of l0-year battery life (wananty)
o Minimum of 7,500 battery cycle life to accommodate for daily load cycling
o Ability to chargeidischarge multiple times a day
o Full dispatch control by PacifiCorp to meet the needs of the program
o Proper UL or equivalent safety certifications for residential and commercial
applications
As technology evolves and new products become available, it is anticipated more batteries will
become eligible. The Company will maintain an updated list of eligible batteries and other
requirements for participation on the Wattsmart Battery program website.
DISPATCH PERIOD
20. The Company shall have the right to dispatch the Wattsmart Battery system
based on the following criteria:
APPLICATION OF
ROCKY MOI.INTAIN POWER
Page 8
. Daily load cycling for peak management
o Utilized for traditional demand response, frequency reserve, contingency
reserve, regulation reserves, regional grid management, backup power and
other ancillary needs.
o Dispatch Days: Monday through Sunday, including holidays, year-round.
o Dispatch Duration: Dispatches may be held multiple times per day up to two
full duty cycles of the battery.
At the outset of the Wattsmart Battery Program, batteries will be dispatched to off-set
customers' load, as discussed in the Load Shaping paragraph above. As the Program evolves
and matures, the Company intends to add capability to the timing of dispatch, such as charging
batteries during the day with excess solar and exporting the solar energy during peak times, in
order to maximize benefits for all parties.
21. The Company may dispatch batteries to the system as necessary without
advanced notice. The Company will not drain batteries below l0 percent capacity to ensure
customers retain a minimum level for emergency backup. The DBGMS and integration into
the Company's Energy Management System makes this possible to manage. Additionally,
Wattsmart Battery dispatch events will be managed to minimize use of the battery system
during or prior to an event that is expected to cause system outages.
22. In the event of a local outage, the battery will be used as backup power for the
customer. While there are many factors that influence customer load, including battery size,
house size, solar affay, time of year, etc., it is estimated that 10 percent capacity will provide
1-8 hours of emergency backup power for an average customer. The Company will continually
evaluate this percentage and update if necessary, to ensure the batteries are available when
needed for customers.
APPLICATION OF
ROCKY MOUNTAIN POWER
Page 9
NEW SCHEDULE II4 TARIFF
23. Attached hereto as Exhibit A is a proposed new Electric Service Schedule 114
- Load Management Program, to enable the implementation of the Class I Wattsmart Battery
program. Additionally, consistent with the flexible tariffs for the Company's Class 2 DSM
programs, attached hereto as Exhibit B are the proposed incentive tables and other program
information that will be managed pursuant to the flexible tariff process.
TRADE ALLY NETWORK
24. The Company may establish and utilize a qualified Trade Ally Network to
promote the Wattsmart Battery program, educate customers on batteries, and install the battery
equipment for customers. Establishing this network may include identifying and recruiting
vendors that can comply with all participation requirements, providing Program and technical
training to vendors, and providing vendor sales training and support on an ongoing basis. For
the first year or two of the Program the Company will seek to qualiff and train trade allies
while the Program is ramping up.
25. Participating vendors may have their information promoted on the Company's
website and may have access to marketing materials and support, ongoing training, and
program tools. Participating vendors may also receive periodic vendor performance details to
provide feedback and encourage vendors to continually improve. Highly successful vendors
may receive additional benefits, including improved visibility and enhanced co-branding with
the Company. Examples of performance metrics that may entitle vendors to added benefits are
as follows:
o Industry Certification
o Level of Participation
o Customersatisfaction
o Program satisfaction
APPLICATION OF
ROCKY MOUNTAIN POWER
Page l0
o Project Quality Assurance
COST EFFECTIVENESS
26. The cost effectiveness analysis for the Wattsmart Battery program is attached
hereto as Confidential Exhibit C, based on the maximum "up to" incentive levels. As avoided
costs are considered proprietary on load control programs, the cost effectiveness results are
provided below with a 'opass" designation, which equates to a benefit to cost ratio of 1.0 or
better. Due to the nature of demand response, and consistent with the cost effectiveness
methodology for other demand response programs, the Participant Cost Test is not applicable.
The Wattsmart Battery program is expected to be cost effective under all other scenarios.
Table 4 - Wattsmart Batterv Proeram Level Cost Effectiveness Results
BenefiUCost Test Benefrt/Cost Ratio
PacifiCorp Total Resource Cost Test (PTRC) +
Conservation Adder Pass
Total Resource Cost Test ORC) No Adder Pass
Utility Cost Test (UCT)Pass
Rate Impact Test (RIM)Pass
Participant Cost Test (PCT)N/A
27.
COMMUNICATIONS
Communications regarding this Application should be addressed to:
Ted Weston
Michael Snow
1407 W. North Temple, Suite 330
Salt Lake City, Utah 84116
Telephone: (80 l) 220-2963
Email : ted. weston(@pacillcorp.com
michael. snorvfDpaci llcorD.conl
Emily Wegener
1407 W. North Temple, Suite 320
Salt Lake City, Utah 84116
Telephone: [phone]
Email : em i Iy- . we generi4)pac i fi corp. conr
APPLICATION OF
ROCKY MOLTNTAIN POWER
Page 11
In addition, the Company respectfully requests that all data requests regarding this matter be
addressed to one or more of the following:
By e-mail (preferred) [e-mail]
By regular mail Data Request Response Center
PacifiCorp
825 NE Multnomah, Suite 2000
Portland, OR 97232
MODIFIED PROCEDURE
28. The Company believes that consideration of the proposals contained in this
Application do not require an evidentiary proceeding, and accordingly requests that this
Application be processed under Modified Procedure, RP 201 et seq. allowing for consideration
of these issues by written submissions rather than by an evidentiary hearing. If, however, the
Commission determines that an evidentiary proceeding is required the Company stands ready
to provide supporting testimony.
CONCLUSION
WHEREFORE, Rocky Mountain Power respectfully requests that the Commission
issue an Order authorizing the implementation of a battery demand response progftLm under
the new Electric Service Schedule 114 - Load Management Program within the demand side
management portfolio as described herein, with an October 15,2021, effective date.
DATED this l5s day of July,202l.
Respectfully submitted,
By
Emily Wegener
Attorney for Rocky Mountain Power
APPLICATION OF
ROCKY MOUNTAIN POWER
Page 12
ROCKY MOUNTAIN
POWER
A DMSION OF PACIFICORP
LP.U.C. No. I Original Sheet No. 114.1
ROCKY MOI,]NTAIN POWER
ELECTRIC SERVICE SCHEDULE NO. II4
STATE OF IDAHO
Load Management Program
APPLICABLE: This tariff is applicable to eligible Customers who have premises located in
designated areas. Customers served by the Company in the state of ldaho taking service under the
Company's electric service schedules listed on Schedule l9l - Customer Efficiency Services Rate
Adjustment located within the designated areas are eligible to participate in a Load Management Program
(Program).
PTIRPOSE: To manage electric loads through a Company-dispatched Direct Load Control
System (System).
PROGRAM DESCRIPTION: A detailed description of the Program(s) is found on the
Company website.
CUSTOMER PARTICIPATION: Participating premises are considered Program participants
for the duration of the Program(s). Customers may cancel their participation in the Program(s) at any
time. The Company or its Program contractors shall have the right to quali$ program participants, at
their sole discretion based on criteria the Company or Program contractors consider necessary to ensure
the effective operation of the Program(s) and utility System. Program details can be viewed on the
Company's website.
PROVISIONS OF SERVICE:
l. Qualiffing Equipment or Services, incentive amounts, and participation procedures will
be listed on the Load Management Program website.2. Incentive delivery may vary by technology and may include cash payments and/or bill
credits.
3. Incentives may be offered year-round or for selected time periods.
4. Incentive offer availability, incentive levels, and Qualiffing Equipment or Services may
be changed to reflect changing codes and standards, sales volumes, quality assurance data,
or to enhance program cost effectiveness.
5. All changes will occur with a minimum of 45 days notice and be prominently displayed
as a change on the Company's website.
ELECTRIC SERVICE REGULATIONS: Service underthis Schedule will be in accordance with
the terms of the Elecfic Service Agreement between the Customer and the Company. The Electric Service
Regulations of the Company on file with and approved by the Public Service Commission of the State of
Utah, including future applicable amendments, will be considered as forming apart of and incorporated in
said Agreement.
Submitted Under Case No. PAC-E-21-16
X'ILED: Ju,ly 15,2021 EFFECTIYE: October 15, 2021
Idaho Load Management Program
This document includes the following sections:
o Definitions of terms used in Schedule 114 and other program documents
o Incentives - General Information
o Dispatch Parameterso Incentive Tables
DEFINITIONS
Annual Participation Incentive: Incentives participating customers may receive for ongoing
active participation in a Load Management program.
Available Dispatch Hours: Daily timeframe within which the Company may dispatch its load
control system(s).
Customer: Any party who has applied for, been accepted, and receives service at the real property,
or is the electricity user at the real property.
Dispatch Days: The days upon which the Company may or may not dispatch its load control
system.
Dispatch Duration: The duration of time that load control events may be dispatched for.
Dispatch Parameters: The criteria within which the Company may dispatch its load control
system(s).
Dispatch Period: The calendar year timeframe within which the Company may dispatch its load
control system(s).
Enrollment Incentive: Upfront incentives participating customers may receive upon their
enrollment in a Load Management program.
Incentive: Payments of money or bill credits made by Company to Owner or Customer for
participation in a Load Management offer.
Incentive Application: An application submitted by Owner or Customer to Company for
Incentives.
Incentive Offer Letter: An offer made by Company and acknowledged by Owner or Customer
providing for Company to furnish Incentives for a Load Management Project.
Maximum Dispatch Hours: The maximum amount of time the Company may dispatch its load
control system annually.
Owner: The person who has both legal and beneficial title to the real property and is the mortgager
under a duly recorded mortgage of real property, the trustor under a duly recorded deed of trust.
INCENTI\TES _ GENERAL INT'ORMATION
Incentives for Measures Listed in the Incentive Tables
Dollar values listed in the incentive tables are the maximum amounts approved for programs.
Incentive amounts that customers may actually receive are managed and available on the
Company's website, which may be less than the approved maximum amounts. Incentives are
subject to change through notices posted on the Company's website.
Custom Incentives
Where custom is listed in the incentive tables, custom incentives may be considered for customers
with custom projects.
Program Contractors
Program contractors may provide additional consideration, at no additional cost to the Company
or its customers, to encourage enrollment in a Load Management Program. Such consideration
may include, but is not limited to, gift cards or other efforts used to increase Customer interest in
a program.
DISPATCH PARAMETERS
The Company shall have the right to dispatch System(s) according to the following criteria:
Wattsmart Batteries
Dispatch Period January I throueh December 31
Available Disoatch Hours 12:00am to 1 1 :59pm Mountain Time
Maximum Dispatch lfours N/A
Disuatch Davs Mondav throueh Sundav
Dispatch Duration Events may be held multiple times per day up to two fuII
battery duty cycles
ln the event of a system emergency, Rocky Mountain Power may,at its discretion, expand the
dispatch criteria beyond the parameters listed. Emergency events may be used to satisff
requirements of the North American Electric Reliability Corporation (NERC) standard BAL-002-
WECC-2 for Contingency Reserve Obligation (CRO) and may be deployed when the utility is
experiencing a qualiffing event as defined by the Northwest Power Pool.
INCENTIVE TABLES
Table I - Wattsmart Batteries
l. Enroltnent Incentives are capped at70Yo ofbattery equipment costs and available to new battery purchases only.
2. Participation Incentives are eligible to be applied towards monthly energy charges. Customers will still be
responsible for fixed customer charges
3. Applicable to new batteries after the commitrnent term or existing batteries where the enrolLrnent incentive and
commifrnent tenn is not applicable. Participation Incentives are eligible to be applied towards monthly energy
charges. Customers will still be responsible for fxed customer charges.
Load Management
Program
Participating
Equipment
Maximum Incentive t'uD to"
Enrollment
Incentivel
Annual Participation
Incentive During
Commitment Term2
Annual Participation
Incentives
Wattsmart Batteries
Residential Batteries $150/kWx Annual
Commitment Term $lslkw $50/krtl/
Commercial
Batteries
$150/kW x Annual
Commitnent Terrn $r5/kw $so/kw
Custom Custom
THIS ATTACHMENT IS CONFIDENTIAL IN ITS
ENTIRETY AND IS PROVIDED UNDER SEPARATE
COVER