20220106Reply Comments.pdf

1407 W. North Temple, Suite 330 Salt Lake City, Utah 84116
January 6, 2022
VIA ELECTRONIC FILING
Idaho Public Utilities Commission
11331 W. Chinden Blvd.
Building 8 Suite 201A Boise, ID 83714
Attn: Jan Noriyuki
Commission Secretary
RE: Case No. PAC-E-21-16 In the Matter of the Application of Rocky Mountain Power For Authority to Implement a Battery Demand Response Program
Reply Comments
Please find enclosed Rocky Mountain Power’s Reply Comments in the above referenced matter.
Informal questions related to this matter may be directed to Ted Weston at [phone] or me
at [phone].
Sincerely,
Michael S. Snow Manager, Regulatory Affairs
Enclosures
RECEIVED
2022 JAN 06 PM 2:06
IDAHO PUBLIC
UTILITIES COMMISSION
REPLY COMMENTS OF Page 1 ROCKY MOUNTAIN POWER
Emily Wegener (ISB# 11614) Rocky Mountain Power 1407 West North Temple, Suite 320 Salt Lake City, Utah 84116 Telephone: [phone]
Email: [e-mail] Attorney for Rocky Mountain Power
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION

IN THE MATTER OF THE APPLICATION
OF ROCKY MOUNTAIN POWER FOR
AUTHORITY TO
PROGRAM
) CASE NO. PAC-E-21-16
)
) REPLY COMMENTS
)
COMES NOW, Rocky Mountain Power, a division of PacifiCorp (the “Company”), in
accordance with RP 052 and RP 201, et. seq., hereby respectfully submits reply comments to
the Idaho Public Utilities Commission (the “Commission”) in the above-referenced matter.
BACKGROUND
1. On October 15, 2021, the Commission issued a Notice of Modified Procedure
in Order No. 35197 for the above referenced matter, allowing parties to file comments by
December 16, 2021, with the Company’s reply comments due by January 6, 2022. Commission
Staff (“Staff”) filed comments December 16, 2021. Staff supports the Company’s Application
to implement a Battery Demand Response Program (“Program”) with recommended
adjustments, including running the Program initially as a Pilot, including updated definitions
within Schedule 114, and adding annual reporting requirements. The Company provides these
reply comments in response to comments filed by Staff.
REPLY COMMENTS
2. The Company is agreeable to Staff’s recommendation to implement the
Program as a pilot for five years. However, it should be noted that the proposed Program is an
REPLY COMMENTS OF Page 2 ROCKY MOUNTAIN POWER
expansion of the already established Wattsmart Batteries program offered in Utah, as
referenced in the Company’s response to Staff’s Set 2 Data Request No. 25. Attached hereto
as Exhibit A is an updated Schedule 114 tariff sheet to reflect the pilot status of the program.
Attached hereto as Exhibit B are updated flexible tariff materials to include a definition for
continuous output and remove the custom incentive option, per Staff’s recommendations. The
Company will also ensure the Program website includes information on the incentive structure
and other Program details to help customers be informed and educated on Program offerings
and requirements. Additionally, while the Company acknowledges Staff’s concerns and
recommendation for cost effectiveness assumptions that are more specific towards Idaho, the
established Wattsmart Batteries program is designed and operated as a PacifiCorp system
resource. The Company’s intent is to expand the Wattsmart Battery program to multiple
PacifiCorp states and to be managed, reported on, and valued with continuity. The Company
acknowledges the cost effectiveness and system benefits will evolve over time and we will
share results in reporting and discuss with Staff during subsequent routine meetings held for
demand side management updates. The Company believes the Wattsmart Battery program can
be operated cost effectively.
3. With respect to incentives and the Program structure, the Company will make
adjustments on an annual basis per Staff’s recommendation. However, mid-year adjustments
may also be made if necessary in response to market conditions (e.g. changes in materials
costs, product availability, price competition, etc.) and to stay in alignment with the Program’s
targets and budget. The Company will work with Staff if mid-year adjustments are needed
beyond the planned annual timeframe.

REPLY COMMENTS OF Page 3 ROCKY MOUNTAIN POWER
4. With respect to annual reporting, the Company will include a report of Program
details as part of the Company’s existing Demand Side Management report, currently due by
May 1st annually. Some of the key deliverables and metrics mentioned in Attachment A to
Staff’s comments may not be practicable to track and report on due to the limitations of the
Company’s systems. The Company will discuss further with Staff and make best efforts to
include the requested metrics in annual reporting.
REQUEST FOR RELIEF
WHEREFORE, Rocky Mountain Power respectfully requests that the Commission
approve the Company’s Application to implement a battery demand response program as
discussed herein and supported by Staff.

DATED this 6th day of January, 2022.

Respectfully submitted,

By _______________________________
Emily Wegener Attorney for Rocky Mountain Power

Exhibit A

I.P.U.C. No. 1 Original Sheet No. 114.1

Submitted Under Case No. PAC-E-21-16

FILED: January 6, 2022 EFFECTIVE: TBD
ROCKY MOUNTAIN POWER

ELECTRIC SERVICE SCHEDULE NO. 114

STATE OF IDAHO
_____________________

Load Management Pilot 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 Idaho taking service under the
Company’s electric service schedules listed on Schedule 191 – Customer Efficiency Services Rate
Adjustment located within the designated areas are eligible to participate in a Load Management Program
(Program).

PURPOSE: 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 qualify 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:
1. Qualifying Equipment or Services, incentive amounts, and participation procedures will
be listed on the 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 Qualifying 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 under this Schedule will be in accordance with
the terms of the Electric 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 a part of and incorporated in
said Agreement.

Exhibit B
Idaho Load Management Pilot Program

This document includes the following sections:
 Definitions of terms used in Schedule 114 and other program documents
 Incentives – General Information
 Dispatch Parameters
 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).

Continuous Output: Inverter is capable of discharging at this rate of power (kW) without
interruption or reduction, continuously, when connected to the utility grid and under normal
conditions, as long as the battery’s state of charge allows.

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.

INCENTIVES – GENERAL INFORMATION

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 Januar 1 throu h December 31
Available Dispatch Hours 12:00am to 11:59pm Moutain Time
Maximum Dispatch Hours N/A
Dispatch Days Monda throu h Sunda
Dispatch Duration Events may be held multiple times per day up to two full
atter dut c cles

In 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 satisfy
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 qualifying event as defined by the Northwest Power Pool.

INCENTIVE TABLES

Table 1 – Wattsmart Batteries
Load Management
Program
Participating
Equipment
Maximum Incentive “up to”
Enrollment
Incentive1
Annual Participation
Incentive During
Commitment Term2
Annual Participation
Incentive3
Wattsmart Batteries
Residential Batteries $150/kW x Annual
Commitment Ter $15/kW $50/kW
Commercial
Batteries
$150/kW x Annual
Commitment Ter $15/kW $50/kW
Custom Custom
1. Enrollment Incentives are capped at 70% of battery 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 commitment term or existing batteries where the enrollment incentive and
commitment term is not applicable. Participation Incentives are eligible to be applied towards monthly energy
charges. Customers will still be responsible for fixed customer charges.

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CERTIFICATE OF SERVICE
I hereby certify that on this day, I caused to be served, via email, a true and correct copy of Reply Comments in Docket PAC-E-21-16 to the following: Service List
Ted Weston
Michael Snow PacifiCorp/ dba Rocky Mountain Power 1407 West North Temple Suite 330 Salt Lake City, UT
84116 E-Mail: [e-mail]
PacifiCorp/ dba Rocky Mountain Power 1407 West North Temple Suite 320 Salt Lake City,
UT 84116 E-Mail: [e-mail]
Eric L. Olsen Echo Hawk & Olsen PLLC 505 Pershing Ave., Suite 100 PO Box 6119 Pocatello, ID 83205 E-Mail:

Commission Staff
Deputy Attorney General Idaho Public Utilities Commission 11331 W. Chinden Blvd., Bldg No. 8,
Suite 201-A (83714) PO Box 83720 Boise, ID 83720-0074

Dated this 6th day of January, 2022. __________________________________
Mary Penfield
Adviser, Regulation