20211216Comments-Redacted.pdf

ERICK SHANER
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, TDAHO 83720-0074
[phone]
IDAHO BAR NO. 5214
'1.[{);ivrD
:irii *[]: lt] PI{ 3:56
(,
$$r0l+
Street Address for Express Mail:
I 133I W CHINDEN BLVD, BLDG 8, SUITE 2OI.A
BOISE,ID 83714
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMNflSSION
IN THE MATTER OF THE APPLICATION
OF ROCKY MOUNTAIN POWER FOR
AUTHORITY TO IMPLEMENT A BATTERY
DEMAI\ID RESPONSE PROGRAM
CASE NO. PAC.E.2I.I6
REDACTED COMMENTS OF
THE COMMISSION STATF
STAFF OF the Idaho Public Utilities Commission, by and through its attorney of record,
Erick Shaner, Deputy Attomey General, submits the following comments:
BACKGROUNI)
On July 15,2021, PacifiCorp dba Rocky Mountain Power ("Company") applied to the
Commission for an Order approving a new and flexible "Schedule 114 load management tariff
within the demand side management (*DSM") portfolio", effective October 15,2021.
Applicationatl,2,and 12. Thenewtariffwouldfundimplementationofa"Class I battery
demand response prog&m ("Wattsmart Battery" or "Program")." Id. at l. T}lre Company
requested an October 15,2021, effective date and asked that the case be processed by Modified
Procedure. Id. at 12.
The Company requested a flexible tariffthat will allow the company'to manage and
publish Program details on the Company's website, with hard copies provided to customers upon
)
)
)
)
)
)
)
IREDACTED STAFF COMMENTS DECEMBER 16,2O2I
request, while allowing for adequate Staffinput. Before the Company makes Program changes,
it will provide Staffwith its intended modifications and allow sufficient time to resolve any Staff
concerns. Id. at2.After Staffs concerns are resolved, the Company will post the final set of
changes for at least 45 days before the changes are to take effect." .Id.
The Company intends for the battery Program to promote and provide incentive for
customers to install individual batteries that will be integrated into their system and used for grid
management. Id. at 3. The Company states that this will benefit customers and the grid and
create opportunities in utility grid management, load shaping, and utility integration of behind-
the-meter batteries. Id. at3-4.
The Company intends to make the Program available to residential and commercial
customers. Initial participation will likely be residential customers with solar generation. Id. at 4.
If customers install eligible battery equipment and allow the Company to use the battery for the
grid, customers will be compensated with enrollment incentives and annual credits to their bills.
/7. Customers who already have eligible batteries may also be able to participate in the Prograrn.
Id. at 5.
The Company projects that by 2029, the Program will provide about l0 MW of battery
demand response. Id. at 7 . Estimated Program costs in 2022 are expected to be $3 I 5,000,
$630,000 in2023,and $1,006,000 in 2024.ld.
The Company will require participants in the Program to have a reliable internet
connection, a Wi-Fi network, and eligible battery-related equipment to facilitate communication
withthe gid.Id.at8.
The Company wants the right to dispatch the Wattsmart Battery system based on certain
criteria and it may establish a qualified Trade Ally Network to promote the Program, educate
customers, and install battery equipment. Id. at9-10.
The Company has provided cost effective analysis data for the Commission to review as
part of this process. Id. at ll.
STAFF ANALYSN
Staffexamined the Company's Application, workpapers, and additional information
provided by the Company. The Company is requesting authority to implement a Class I battery
demand response program under Schedule 114 Load Management Tariffwithin the demand side
management ("DSM') portfolio. Based on its review, Staffrecommends that the Wattsmart
2REDACTED STAFF COMMENTS DECEMBER 16,202I
Battery program proposed by the Company be implemented as a pilot progftm for 5 years with
incentive payouts for 9 years from the effective date of a Commission order. Staffrecommends
that the Company update Schedule I 14 to reflect the pilot program. Additionally, if it is the
Company's intent to proceed with the Program beyond the pilot period" Staffrecommends the
Company file a new case with the Commission requesting approval to extend the pilot or make
the Program permanent.
Program Specifications
Under the Company's proposal, Wattsmart Battery customers will have the potential to
receive multiple incentives over the course of the life of the battery. The Company states:
Enrollment incentives will be based on the kW capacity of the enrolled battery,
multiplied by the commitnent 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 prograrn
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.
Application at 6.
The Company later clarified that the participation incentives kW capacity of the enrolled
battery is based on the "continuous output of the battery." Response to Production Request No.
la(c). The Company describes continuous output as "the output kilowatts (*kV/") of the battery
that is accessible to the Company over a continuous timeframe." Response to Production
Request No. 44.
To participate in the Program, eligible batteries must: (l) b€ able to integrate into the
Company's Distributed Battery Grid Management Solution (*DBGMS"); (2) be a Utility grade
banery with a minimum 4 kW /10 kWh; (3) have a minimum l0-year battery life warranty; (4)
have a minimum of 7,500 battery cycle life; (5) be able to charge and discharge multiple times a
day; (6) have full dispatch control by the Company; and (7) have proper UL or equivalent safety
certifications for residential and commercial applications. Application at 8. 'oCurrently, only
Sonnen batteries are eligible to participate in the Wattsmart Battery program." Response to
Production Request No. 6.
The Company indicated that avoided costs are considered proprietary on load control
progftrms, so the cost-effectiveness results are provided with a designation of "pass" or "fail". A
3REDACTED STAFF COMMENTS DECEMBER 16,2021
cost-effectiveness result of "pass" represents a benefit-to-cost ratio of one or greater.
Application at I l. The Company reported that the Program is cost-effective with a pass
designation under the following tests: Utility Cost Test (*UCT"'), Total Resource Cost Test
("TRC"), PacifiCorp TRC, and Rate Impact Measure Test.
The Company's Exhibit C and Response to Production Request No. 5 indicate that the
UCT benefit to cost ratio is I fn" Company modeled a2}-year measure life for batteries and
used a "Value per kW-Yr" of Iitt the first year of the calculation. The Value per kW-Yr
of benefit used for the Program is from the Company's Utah Cool Keeper demand response
program. The Company provides a forward outlook for the Program for20 years until 2041 and
models new customer enrollment in the Program at an expected 100 new customersin2022,
which continues to grow by 100 additional customers each year until2025. The analysis expects
475 new customer enrolhnents p{er year from2026 to 2041. The Company predicts it will have
I customers enrolled in the Program uv I accounting for I kW of battery storage.
Cost-Efrectiveness Concerns
Participation
During the initial phase of the Program, the Company will only allow batteries paired
with solar ganeration to participate.l tn Response to Production Request No. 14, the Company
stated "it will be more challenging to get customers with existing solar to participate in the
progr.rm than customers without existing solar, thus requiring a lower incentive for customers
who install solar" after the effective date of a Final Ordef. tn Response to Production Request
No. 48, the Company also stated it is not known how many existing solar customers would
participate, but could range between 10 to 50 percent or more.
In 2019 and2020, the Company averaged 285 solar installations per year on Residential
Service Schedule No. 13. The Company projects 100 residential participants in the Program's
I "Customers who participate in the proposed Wattsmart Battery program will initially be required to be enrolled in
the Company's Net Metering Program." Response to Production Request No. 22.
2 The Company had initially proposed a Sl00/kW incentive for customers who installed solar after September l,
2021, and a $150/kW incentive for customers who installed prior to September 1,2021. Due to the cancellation of
the effective date, OrderNo. 35139, the Company stated, "now that the program's effective date has been pushed to
what will likely be the first quarter of 2022, the additional $50/kW incentive will be applicable to customers who
install solar before the effective date of the program, rather than the previously stated September l't date." Response
to Production Request No. 43(b).
3 See Response to Production Request No. I l.
4REDACTED STAFF COMMENTS DECEMBER 16,2O2I
first year and increasing participation each year after. Staffis concerned the Company is unable
to support its participation estimates.
Solar involves a substantial financial commitment by a customer. The additional cost of
installing a battery to provide backup power and to shift load makes the investment riskier for
customers wanting to potentially recover their investrnent in a solar plus battery system. Staffis
concerned that due to the high cost to install a battery system that the Company's participation
estimates will not be achieved; thus, cost-effectiveness of the Program will be affected. [f costs
decrease for residential batteries, participation levels could be achieved, but until that occurs,
participation in the Prog arn may be inadequate.
Much of the Program is reliant upon future solar installations. Potential changes
stemming from the results of the on-site generation study currently being conducted pursuant to
Order No. 34753, Case No. PAC-E-19-08, could impact solar growth and the potential
participation in the Program. Through a pilot program, the Company can get the relevant data on
the Program including actual estimates of customer battery adoption, battery life, and additional
information to design a long-term successfirl program.
Battery Technologt
In its Application, the Company states "the battery storage industry is still in its infancy,
and there is a lack of standards for utility grid integration from both a safety and operational
perspective." Id at 34. Currently, there is only one battery manufacturer eligible to participate in
the Prograrn. The Company states that "battery storage technology is still relatively new and
continuous innovation is expected to occur in the short and long-term. The Company expects
costs to decrease and options for additional batteries to become available in the next I to 3
years." See Company Response to Production Request No. 26(c). Because the battery storage
industry is still in its infancy, the industry trend is dilficult to predict. Operating the Program as
a pilot will allow the industy to mature and provide the Company with sufficient data to validate
its assumptions.
If the Company's statement of "additional batteries to be available in the next I to 3
years" holds true, a 5-year pilot program would allow ample time for additional battery
manufacturers to join the Program, thus creating greater opportunities for customers to pair
batteries with their home and allowing the Company, Commission, and other interested parties
5REDACTED STAFF COMMENTS DECEMBER 16,2O2I
the ability to reassess key Prograrn characteristics with multiple battery manufacturers that can
potentially participate in the Program.
Measure Life
The Company's cost-effectiveness calculations for the Program use a 20-year measure
life. Staffasked the Company to provide supporting documents, workpapers, and/or research
that support a20-year battery measure life. See Production Request No. 37. In response, the
Company was unable to provide any documents, workpapers, or research supporting the 20-year
measure life for the batteries and state4 "battery technology is expected to last beyond the
manufacturer's warranty." However, that does not justifr a measure life double the minimum
warranty. Staffis concerned about over-estimating measure life for the Program with no
supporting documentation for the assumption being used in the Company's cost-effectiveness
calculations. The Program would be cost-effective using a lS-year measure life; however, if the
battery life does not extend beyond the manufacturer's l0-year warranty, the Program would not
be cost-effective.
Additionally, the Company's cost-effectiveness calculations indicate the Program is not
cost-effective until I h I the Company is reporting the Program to have a benefit-to-
cost ratio ofl
Currently, the Company is modeling battery life using the SonnenCore, Sonnen Eco, and
Sonnen Ecolinx batteries, which have a cell chemisty of lithium iron phosphate.a However, as
new battery manufacturers participate in the Program, the new manufacfurer's batteries will be
composed of different materials and cell chemistries, thus having a different battery life than
modeled for the Company. For example, the Tesla Powerwall battery is a residential or light
commercial use battery that meets some of the specifications required by the Company. The
battery is composed of a rechargeable lithium ion baffery that has an energy capacity of 13.5
kwh with 5.8 kW continuous output and has a l0-year minimum waranty.s Recent research
authored by the Pacific Northwest National Laboratory estimates lithium-ion battery life at l0
a [n Response to Production Request No. 37, the Company indicated the pmgram modeled Sonnen Core, Sonnen
Eco, and Sonnen Ecolinx batteries. In the attachment provided to Production Request No. 37, battery specifications
for the SonnenCore battery indicate the batteries have a cell chemistry of lithium iron phosphate.
5 Tesla Powerwall battery specifications sourced from https://www.tesla.com/powerwall and from
httos://www.tesla.com/sites/default/files/pdfs/pswerwall/Powerwall%202_AC_Datasheet_en northamerica.ndi
6REDACTED STAFF COMMENTS DECEMBER 16,202I
years.6 With the ability for additional battery manufacturers to participate in the Program, Staff
is concerned that battery usefrrl lives will vary between manufacturers and could impact the cost-
effectiveness of the Program.
ln addition, Staffis concerned with the use of Utah Cool Keeper's
I used to model the Program. The Program should be modeled using Idaho specific
values. The Company describes the Program as an advanced demand response progrmT with
the ability to provide multiple utility grid management practices including:
(T)raditional demand response, frequency reserve, contingency reserve,
regulation reserves, regional grid management, backup power and other
ancillary benefits in addition to reducing peak load on the electric
system...Initially, batteries will be used to off-set customers' load, but as
the Program evolves and matures, the Company intends to add other
capabilities.
With the Company's ability to provide grid management capabilities outside of
raditional demand response, the Company needs to evaluate the'talue per kW year" based on
the benefits that it can provide. This is something that can be conducted during the pilot
proposed by Staff. Through the pilot, the Company should evaluate the 'ovalue per kW year" for
the additional gdd management capabilities the Prograrn is able to provide specifically to Idaho.
Battery Degradation
Staffis concerned that battery degradation will impact the performance of the Program.
The Company has the ability to use the batteries for load shifting and multiple utility grid
managements practices 24 hours pr dayl365 days per year. With the Program's ability to
provide multiple utility grid management practices beyond a traditional demand response
program, batteries are expected to be used frequently, which will result in accelerated rates of
battery degradation over the life of the battery.
6 Enerry Storage Technology and Cost Characterization Report at Table ES.l,
httos : //enereystorage.nnn l. gov/pdf/PNN L-2 8 866.pdf
7 The Company describes advanced demand response as "providing a flexible resource which is automatically
dispatched real-time to respond to large grid events with frequency response." Whereas "haditional demand
response events are typicalty pre-scheduled day ahead or several hours in advance when system load is expected to
peak." Response to Production Request No. 38.
8 The Company describes Utility Grid Management as "traditional demand response, frequency reserve, contingency
reserve, regulation reserves, regional grid managemen! backup power and other ancillary benefits in addition to
reducing peak load on the electric system." Application at 3.
7REDACTED STAFF COMMENTS DECEMBER 16,2O2I
To help protect against battery degradation concerns, the Company has established
criteria for batteries, such as a minimun lO-year battery warranty and a minimum of 7,500
battery cycling life for eligible equipment to quali$. However, this does not remediate all
concerns with battery degradation. A battery may be able to cycle beyond the minimum 7,500
battery cycle life required by the Company, but due to battery degradation" batteries may not be
able to provide continuous output of the original enrolled amount and as specified by the battery
manufacturers for a brand new battery. For example, a brand new SonnenCore battery has the
capability of providing 4.8 kW of continuous output and usable capacity of 10 kWh; however, in
year I I due to battery degradation, that battery may not provide that usable capacity and
continuous output as originally installed.
In the Company's cost-effectiveness workbooh the Company models enrolled battery
capacity output to be constant throughout the 20-year benefit period and the workbook does not
account for battery degradation. Staffanticipates that due to battery degradation, the Company's
enrolled Program participant's continuous output will decline with the age of the battery, thus
resulting in a smaller amount of kW available than originally anticipated. Operating the Program
as a pilot provides the Company the opportunity to study the impact of battery degradation on the
Program' s cost-effectiveness.
Pilot Proposal
Staffis encouraged by the opportunity of a battery demand response progftrm and a
successful Program can help actively manage the solar penetration and provide a more resilient
and reliant grid. However, given the concerns mentioned above, Staff recommends the Program
be conducted as a pilot in order to help secure a long-term successful battery demand response
progftlm. The pilot will provide necessary data to inforrn decisions and improve the assumptions
used by the Company.
In Attachment A, Staff provides program changes, specifications, and annual reporting
requirements for its proposed pilot program. Staffexpects that the Company will actively
manage the Program as it would its other DSM programs, make its best effons to increase cost-
effectiveness, and increase participation for the program when necessary.
Staffrecommends that the Program be implemented as a pilot, allowing enrollment in the
Program for five years with a potential incentive payout of nine years from the effective date of a
Commission Final Order. Five years of enroltnent in the Program will be able to provide the
8REDACTED STAFF COMMENTS DECEMBER 16,202I
Company, Commission Staff, and other interested parties with adequate data to inform their
decision on rates ofparticipation, types of batteries enrolled in the Program, new battery
manufacturers, cost-effectiveness, and the eflectiveness of the grid management practices used
by the Company. Staffrecommends enrollment in the Program at the end of the fifttr year, and
that customers enrolled during the first five years be able to receive incentives until the end of
the ninth year from an effective date of a Commission final order. An incentive payout until the
end of the ninth year will allow customers enrolled in the Program in year five, the ability to
fulfill their four-year commitment period.
Staff recommends minor changes to the incentive structure originally proposed by the
Company. Staffrecommends the Company not provide a custom incentive option for the
Prograrn during the pilot. The custom incentive option will be difficult to evaluate until further
data and cost-effectiveness calculations can be validated during the pilot period.
Staffrecommends the Company make changes to the Program through the flexible tariff
process during the pilot period. However, Staffrecommends the changes occur on a yearly basis
and that changes to incentive structures be locked for a twelve month period. Yearly changes
will provide ample data to identiS trends in parameters such as participation rates, grid
management practices, and cost-effectiveness of the Program
In addition, Staff recommends that during the pilot period that no Company operated
lease options be provided. In Response to Production Request No. 12, the Company indicated
that the lease option is currently not available and is still being considered. If the Company
wishes to continue the Program and offer a lease option at the end of the pilot period, the
Company should provide a proper lease proposal to the Commission when the Company files its
final report with the Commission.
Staffrecommends the Company file annual reports until the end of the five-year pilot. At
the end of the pilot period, the Company must file a final report to the Commission. Staffhas
provided specific information to be included in the reports in Attachment A, such as
participatiorl Program performance data, and other key Program metrics. tn the final report,
Staffrequests the Company provide a Study or Literature Review of other reputable studies on
battery life, battery degradation, and battery cycle usage. A study or review of the areas outlined
will be necessary for Staffto support the measure life and validate the cost-effectiveness of the
Prograrn.
9REDACTED STAFF COMMENTS DECEMBER 16,202I
The batteries studied or reviewed need to be specific, but not limited to, the types of
batteries being used by the Company for the pilot program. For example, a lithi"m iron
phosphate battery with a usable capacity of 10 kWh and nominal power rating (continuous
output) of 4.8 kW would need to be evaluated. In addition, other residential and commercial
batteries that could be used for a battery demand response program should be evaluated based on
battery cell chemistry, usable capacity, continuous output ratings, and other key specifications
unique to batteries used for the Program.
If the pilot proposal presented by Staffis approved, the Company should file an updated
Schedule No. I 14 to reflect the Program being offered as a pilot. In addition, on the Company's
website and in the updated Tarifi Staffrecommends that the Company provide a clear and
concise definition of continuous output or the per kW used for the incentive structure to alleviate
any customer confusion.
If the Company is seeking to continue the Program after the five-year pilot period, Staff
recommends the Company to file a case with the Commission requesting authority to continue
the Program, including any modifications, along with the final report and studies requested by
Staff. If the Company does not wish to proceed with the Program beyond the pilo! the Company
should continue to provide incentives until the end of the ninth year when the pilot will end.
STAFF RECOMMENDATION
Staff recommends the Wattsmart Battey Demand Response Program be implemented as a
pilot, the Company update Schedule 114 to reflect the pilot program, and provide clear
definitions on how incentives will be paid. Staff recommends the Company file annual reports
as specified in Attachment A. Stafffurther recommends that at the end of the pilot period, or
prior to year five, the Company file a comprehensive report with the Commission and request to
extend the Program beyond the pilot period.
ilt
REDACTED STAFF COMMENTS l0 DECEMBER 16,2021
Respectfully submitted this day of December 2021.
Erick Shaner
Deputy Attomey General
Technical Staff: Taylor Thomas
Travis Culbertson
Yao Yin
i:umisc:commentr/pooe2l. l6escmcyy cqnmena
REDACTED STAFF COMMENTS 11 DECEMBER16,202I
Attachment A: Battery l)emand Response Program (*Program")
Pilot Proposal
PAC-E-21-r6
Pilot Objectives:
The pilot progam is intended to achieve the following objectives:
o "":*,:#;TffiT:il'#:L pa*icipation?
r Are incentive designs driving participation?
o Determine Value of Avoided Cost Based on:
, Grid Management practices
o load shifting, contingency reserves, backup power, etc.
.,.;::;#ffi :;ffi::H;'J::': :;ffi Demand*tru';ffi
d management practice
' Comparative analysis of battery performances based on year and cycling
. Determine proper measure life for residential and commercial batteries.
o Understand how this Program is integrated and used efficiently with on-site
'""":"H;fffiT;:ffir
demand response prosft,m can be leveraged with
the results and outcomes of the PAC-E-I9-08 Study, i.e., export credit
rates, time of use rates, etc.
Pilot Modifications:
l) Pilofi 5 years of Emollrnent and 9 years of potential incentive payout
a) Allow enrollment in Program for up to 5 years from effective date. Customers will
remain on Program untiL (l) end of 9fr year from effective date; (2) customer opts out of
Program; (3) or customers battery is no longer operable before the end of the 96 year.
b) Customers enrolled will b€ able to receive incentives until end of 9n year from the pilot
Prograrn's effective date. Customers will have the ability to continue in the Program if
the Program is extended beyond 5 years.
Attachment A
Case No. PAC-E-21-16
StaffComments
12116/21 Page I of4
c) All incentive values are subject to changes (via flexible taritr) and are not granted legacy
rates. The changes will be posted on the Company's website and will be communicated
electronically at least 45 days prior to the changes
2) Flexible Tarifichanges
a) Must be proposed to Commission Staffwith suflicient review time to allow the
timeframe of the 45 days prior to desired effective date of changes, and changes can
occur on a yearly basis ifneeded. This can occur on a calendar year basis or another
yeady timeframe proposed by the Company.
b) tncentive payments should be locked for a l2-month period. This includes enrollment
and annrral participation incentives.
r) Once historical data is available, continuous output of each battery type should be
reevaluated to ensure it is receiving the specified kW effolled for each specific
battery.
b) Other aspects of Flexible Tariffchanges would be operated as it currently does with other
DSM programs.
2) Incentive Values will remain as the Company proposed in the original Application except
for the Custom option as stated below:
a) Enrollment Incentive for solar insta[ed prior to effective date of Program:
r) $150 per kWt multiplied by Annual Commitment Terrr of 4 years.
b) Enrollment Incentive for solrr instatled after efrective date of Program:
D $100 per kW multiphed by Annual Commitnent Term of 4 years.
c) Annuel Participation Incentive during Commitment term (years 2-4):
r) $15 per kW.
ii) Once historical data is available, continuous output of each battery type should be
reevaluated to ensure it is receiving the specified kW enrolled for each specific
battery.
d) Annual Participetion Incentive after year 4 (after Commitment Term)
i) $50 per kW.
ii) Once historical data is available, continuous output of each battery type and the 4
kWh capacit5r minimnm threshold should be reevaluated to ensure the Company is
I Per kW in the incentives is based on the continuous ouQut of the kilowars ftW) of the bafiery thar is accessible to
the Company over a continuous timeframe. Continuous ouQut is detennined through fte Company's testing.
Attachment A
Case No. PAC-E-21-16
StaffComments
12/16/21 page 2 of 4
receiving the specified output (kW) and that the battery operates above the capacity
threshold (kWh) enrolled foreach specific battery.
e) No Custom fncentive Option will be provided until further evaluation of the
Program.
3) Battery will only be controlled by the Company, no dispatchability by customers during the
pilot.
4) No Company operated lease prograrns. If the Company is seeking to continue the Program
after the pilot and provide a lease option, the Company should provide a proposal for a lease
option for Commission approval.
Key Deliverables and Metrics:
5) Provide Annual Report with key Program metrics. The Annual Report should include:
a) Actual performance data
D Amount of demand response achieved
ii) Amormt of times dispatched and average yearly cycle per battery
iii) Comparative Analysis of exports and consumption usage between Solar with batteries
and solar without batteries (control group)
iv) Average communication failures per battery
v) Provide dara separated by residential and commercial customers
vi) Performance of batteries and demand response operation by each grid management
practicg i.e., load shifting, fr,equency reserves, backup power, etc.
b) Cost-effective calculation for Utility Cost Test
c) Participation:
i) New customers enrollment and solar installs completed
6) Provide frequent updates on new battery manufacturers with the abilrty to integrate into the
Company's Distributed Battery Grid Management Solution ("DBGMS")
7) Provide a linal report at end of year 5 from pilot effective date and year 9 from pilot efrective
date (if Program is no longer continued). The reports should include:
a) Yearly and cumulative Program data
b) Actual Performance Data
i) Amount of demand respoose achieved
Attachment A
Case No. PAC-E-21-16
Staff Comments
12/16/21 Page 3 of 4
ii) Amount of times dispatched and average yearly cycle per battery
iii) Comparative Analysis of exports and consumption usage between Solar with batteries
and solar without batteries
iv) Average communication failtues per battery
v) Provide data separated and by residential and commercial customers
vi) Data on new solar installations with and without batteries (control group)
vii)Performance of batteries and demand response operation by each grid management
practice, i.e., load shifting, frequency reserves, backup power, etc.
c) Cost-effective calculation for Utility Cost Test
d) Participation:
i) New customers enrollment and solar installs completed
e) Provide a Study or Literature Review of other reputable studies on Battery Life, Battery
Degradation, and Battery Cycling usage
i) The batteries studied or reviewed ned to be specific, but not limited, to the types of
batteries being used by the Company for the pilot program. For example, a lithium
iron phosphate battery with a usable capacity of l0 kWh and nominal power rating
(continuous output) of 4.8 kW would need to be evaluated2. In additiorl other
residential and commercial batteries that could be used for a battery demand response
progam should be evaluated based on battery cell chemistry, usable capacity,
continuous output ratings, and other key specffications unique to batteries used for the
Program.
f) Evaluation of a lease option program. If the Company is seeking to continue the Program
after the pilot and provide a lease option, the Company should provide a proper proposal
for a lease option for the Program.
8) At the end of year 5, the Company will provide a final report with key Program metrics
described above. If the Company is seeking to continue the Program beyond the pilo! the
Company should file a new docket with a final report requesting Commission approval to
continue the Program.
2 These batery specifications are from the SonnenCore bafery, which would be a potential ba$ery installed by
custom€rs if fte Commission approves the Program. Batery specifications were pmvided to Staffin Response to
Production Request No. 37 amd can be accessed at httos://sonnenusa.com/enlsonnencore/.
Attachment A
Case No' PAC-E-21-16
Staff Comments
1211612l Page 4 of 4
CERTIT'ICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS I6Ih DAY OF DECEMBER 2021,
SERVED TTIE FOREGOING REDACTED COMMENTS OF THE COMMISSION
STAFF, IN CASE NO. PAC-E-21-16, BY E-MAILING A COPY TIIEREOF, TO TI{E
FOLLOWING:
TED WESTON
MICHAEL SNOW
ROCKY MOUNTAIN POWER
I4O7 WEST NORTH TEMPLE STE 330
SALT LAKE CITY UT 84I 16
E-MAIL: ted.weston@pacifi corp. com
michael.snow@pacifi corp. com
(coNFTDENTTAL)
DATA REQUEST RESPONSE CENTER
E-MAIL OITTLY:
datarequest@pacifi corp. com
(coNFTDENTTAL)
EMILY WEGENER
ROCKY MOUNTAIN POWER
I4O7 WN TEMPLE STE 320
SALT LAKE CIry UT 84I 16
E-MAIL: [e-mail]
(cONFTDENTTAL)
ERIC L. OLSEN
ECHO HAWK & OLSEN PLLC
505 PERSHING AVE., SUITE IOOO
PO BOX 6119
POCATELLO, ID 83205
E-MAIL: [e-mail]
(coNFTDENTTAL)
SECRET
CERTIFICATE OF SERVICE