20230309Reply Comments.pdf

1407 W. North Temple, Suite 330 Salt Lake City, Utah 84116
March 9, 2023

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-22-13 – REPLY COMMENTS IN THE MATTER OF THE APPLICATION OF ROCKY MOUNTAIN POWER FOR AUTHORITY TO IMPLEMENT A COMMERCIAL AND INDUSTRIAL
DEMAND RESPONSE PROGRAM
Please find enclosed Rocky Mountain Power’s Reply Comments in the above referenced matter.
Informal questions related to this matter may be directed to Mark Alder at [phone] or me
at [phone]. Sincerely,

Michael S. Snow Manager, Regulatory Affairs

Enclosures
RECEIVED
2023 March, 9 2:56PM
IDAHO PUBLIC
UTILITIES COMMISSION
REPLY COMMENTS OF Page 1
ROCKY MOUNTAIN POWER
Joseph M. Dallas, (ISB# 10330)
Senior Attorney PacifiCorp 825 NE Multnomah, Suite 2000 Portland, Oregon 97232
Telephone No.: [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 IMPLEMENT A
COMMERCIAL AND INDUSTRIAL
) CASE NO. PAC-E-22-13
)
) 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 December 8, 2022, the Commission issued a Notice of Modified Procedure
in Order No. 35616 for the above referenced matter, allowing parties to file comments by
January 12, 2023, and reply comments by January 26, 2023. On January 11, 2023, the
Commission issued a Noticed of Amended Comment Deadlines in Order No. 35662 for the
above referenced matter, setting new deadlines for comments and reply comments to be due
February 23, 2023, and March 9, 2023, respectively. Comments were filed by Commission
Staff (“Staff”), P4 Production, L.L.C., an affiliate of Bayer Corporation (“Bayer”), and Idaho
Irrigation Pumpers Association, Inc. (“IIPA”) (collectively, the “Parties”), on
February 23, 2023. The Parties do not oppose, generally support, and/or recommend the
Commission authorize the implementation of the Company’s proposed Commercial and
Industrial Demand Response program (the “Program”), with conditions. The Company
provides these reply comments in response to comments filed by the Parties.
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ROCKY MOUNTAIN POWER
REPLY COMMENTS
BAYER
2. Bayer did not oppose the Company’s proposed Program, but requested
additional information regarding how load aggregation would be effective considering the
coordinated response time needed for different load locations. For real-time events, the system
is automatically dispatched without advance notice to shut off customer equipment to curtail
load. For advance notice events, the system automatically sends out notices to the appropriate
on-site personnel, who are responsible for shutting off equipment within 7 minutes of the
automated notice to participate in the called event. Thus, whether a customer is participating
in a real-time or advance notice event from a single site or multiple sites in aggregate, the
Company’s coordination is the same with the utilization of the automated dispatch and notices.
No additional coordinated effort is required by the Company for customers who participate in
aggregate from multiple sites for called events. Given that customer incentives are based on
actual curtailed load, a customer participating in aggregate from multiple sites that fails to shut
off equipment at one or more of their sites within 7 minutes of an advance notice event, will
accordingly receive a reduced incentive. Likewise, customers participating from single sites
will receive incentives commensurate with the realized curtailed load.
IIPA
3. IIPA is generally supportive of the Company’s proposed Program, but
expressed concerns regarding tariff updates, cost effectiveness, and equipment installation and
maintenance costs. To clarify, the Company does not have sole discretion to change maximum
incentive amounts, dispatch parameters, or any information contained within Schedule 114 or
the Load Management Flexible Tariff (“Flexible Tariff”), provided as Exhibit B to the
Company’s Application. Any changes to Schedule 114 would require a new Application and
approval from the Commission. Any changes to the Flexible Tariff would require approval
REPLY COMMENTS OF Page 3
ROCKY MOUNTAIN POWER
from Commission Staff through the established flexible tariff process1 for Demand Side
Management (“DSM”) programs. Program details not contained within Schedule 114 or the
Flexible Tariff will be posted and managed on the Program website as part of the Company’s
day-to-day Program management, consistent with the Company’s other DSM programs.
Additionally, consistent with the maximum up-to incentive process,2 maximum cost effective
amounts are approved and contained within flexible tariffs, while currently offered incentives
at or below the maximum amounts are explicitly provided on the Company website for
customers. This enables the Company to adjust offered incentive levels via 45-day notice
within their pre-approved maximum amounts to timely address market conditions, changes in
material cost, product availability, price-competition, participation levels, and cost
effectiveness. The Company has adjusted the offered incentive levels of its DSM programs
through this process historically between 2018-2022, each instance of which was made known
to Commission Staff via email in addition to being posted on the Company’s website for
customers.
4. IIPA suggests that to address their cost effectiveness concerns, the Company
could include ongoing cost effectiveness tests as part of the Program’s annual reporting. The
Company already includes cost effectiveness test results for all programs as part of its Annual
Energy Efficiency and Peak Reduction Reports (“Annual Reports”). Consistent with historical
practice, the Company will continue to provide annual cost effectiveness test results within its
Annual Reports for all DSM programs, including the proposed Commercial and Industrial
Demand Response program, if approved by the Commission.
1 In the Matter of PacifiCorp DBA Rocky Mountain Power’s Application to Revise Electric Service Schedule 115
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. 2 The maximum up-to incentive process for making changes to pre-approved incentive levels was first established in a flexible tariff update to the then-called Home Energy Savings program approved by Commission Staff and posted on the Company’s website in December 2015.
REPLY COMMENTS OF Page 4
ROCKY MOUNTAIN POWER
5. IIPA’s comments noted that it is unclear whether participating customers or the
Company would be responsible for equipment installations and maintenance, and should be
clearly specified. To clarify, equipment installation and maintenance costs were embedded
within the estimated Program costs in Table 4 of the Company’s Application. Participating
customers will not be responsible for covering equipment and installation costs.
COMMISSION STAFF
6. Staff recommended the Commission authorize the Program with several
conditions, namely the following:
a) Limit the maximum incentive at the levelized 5-year avoided cost. b) Regularly update the levelized 5-year avoided cost for determining the maximum incentive. c) Adjust the maximum incentive within the Flexible Tariff on an annual basis.
d) Set the offered incentive levels at amounts that will retain participation over
time, encourage new participants, and maintain cost effectiveness. e) Update the Flexible Tariff with the dispatch parameters of the Program separated by real-time and advance notice options. f) Include various Program metrics and details in DSM annual reporting and
prudency filings.
7. In response to condition (a), the Company is agreeable to limiting the maximum
incentive at or below the levelized 5-year avoided cost. Accordingly, the Company proposes
to set the maximum incentive at $135/kW for customers who participate in both the real-time
and advance notice options in lieu of the previously proposed $190/kW, and actual offered
incentive amounts paid or credited to customers will not exceed the approved maximum
amounts. The Company’s previously proposed maximum incentive of $125/kW for customers
who participate in either the real-time or advance notice options remains unchanged.
Table 1 – Wattsmart Business Demand Response Program Incentives
Participating Equipment
Real Time Option Commercial and Industrial Custom $125/kW
Commercial and Industrial Custom $135/kW

REPLY COMMENTS OF Page 5
ROCKY MOUNTAIN POWER
8. In response to conditions (b) and (c), the Company agrees to regularly update
the levelized 5-year avoided cost in tandem with new Integrated Resource Plan publications,
and make annual adjustments to the maximum incentive levels, if necessary.
9. In response to condition (d), the Company believes the incentive levels that
were proposed in the Application were set appropriately to retain participation, encourage new
participation, and maintain cost effectiveness of the Program, when accounting for customers’
capacity factors and other variables that would affect the actual adjusted incentive amounts
customers would receive. Notwithstanding, the Company will work with customers to ramp
up participation for the Program within the reduced maximum incentive level recommended
by Staff. Given the Program will be new in the marketplace, it is difficult to know with
certainty if the initially offered incentive levels will retain and encourage participation over
multiple years. Therefore, consistent with its other DSM programs, the Company will monitor
participation levels and other market factors, and adjust offered incentives within the pre-
approved maximum amounts through the established 45-day notice process as necessary to
maintain participation targets and cost effectiveness. If incentive adjustments are necessary in
the early stages of the Program, it is anticipated that offered incentive levels will stabilize as
the Program matures.
10. In response to condition (e), the Company has updated the Flexible Tariff in
Exhibit A, attached hereto, which includes the updated maximum incentive levels consistent
with Table 1 above, and separates dispatch parameters by real-time and advance notice options.
11. In response to condition (f), the Company has historically included all DSM
programs in its annual reporting and prudency filings, and will continue to do so with this
Program, if approved by the Commission. With respect to the voluminous and specific
reporting metrics Staff recommended for the Program, the Company is uncertain at this time
if every metric is available or possible to track and report on. The Company will work
REPLY COMMENTS OF Page 6
ROCKY MOUNTAIN POWER
internally to determine which metrics are practicable and will plan to incorporate them in future
Annual Reports. For any metrics that are unfeasible to provide, due to limitations of the
Company’s systems or undue burden, the Company will discuss with Staff during regularly
scheduled meetings.
REQUEST FOR RELIEF
WHEREFORE, Rocky Mountain Power respectfully requests that the Commission
approve the Company’s Application to implement a Commercial and Industrial Demand
Response program as discussed and updated herein and supported by the Parties.

DATED this 9th Day of March 2023.

Respectfully submitted,

By _______________________________
Joseph M. Dallas Attorney for Rocky Mountain Power

Exhibit A
Idaho Load Management 5-Year Pilot Programs
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. Incentive payouts for the Wattsmart Battery 5-Year Pilot Program will be available through 2031.
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
Available Dispatch Hours
Maximum Dispatch Hours Dispatch Days
Dispatch Duration Events may be held multiple times per day up to two full battery
duty cycles
Load Control Program Dispatch Period Available Dispatch Hours Hours / Events Dispatch Days Dispatch Duration
Wattsmart Batteries 5-Year Pilot January 1 – December 31
12:00am – 11:59pm Mountain Time N/A Monday – Sunday multiple times per day up to two full
Wattsmart Business Demand January 1 – December 31
12:00am – 11:59pm Mountain Time
5 hours / 50 events Monday – Sunday
3 - 7 minutes
Advance Notice 60 hours / 25 events 5 minutes – 4 hours

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 5-Year Pilot Program Incentives
Load Management Program Participating Equipment Enrollment Incentive1 Incentive During 2
Annual Participation Incentive3
Wattsmart Batteries Residential Batteries $15/kW $50/kW
$15/kW $50/kW
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.

Table 2 – Wattsmart Business Demand Response Program Incentives
Participating Equipment Functionality
Wattsmart Business Demand Response
$125/kW Advanced Noticed Dispatch

Idaho Load Management Programs
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. Incentive payouts for the Wattsmart Battery 5-Year Pilot Program will be available through 2031.
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:

Load Control Program Dispatch Period Available Dispatch Hours Hours / Events Dispatch Days Dispatch Duration
Wattsmart Batteries 5-Year Pilot January 1 – December 31
12:00am – 11:59pm Mountain Time N/A Monday – Sunday multiple times per day up to two full
Wattsmart Business Demand January 1 – December 31
12:00am – 11:59pm Mountain Time
5 hours / 50 events Monday – Sunday
3 - 7 minutes
Advance Notice 60 hours / 25 events 5 minutes – 4 hours

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 5-Year Pilot Program Incentives
Load Management
Program
Participating
Equipment Enrollment
Incentive1 Incentive During 2
Annual Participation
Incentive3
Wattsmart Batteries Residential Batteries $15/kW $50/kW
$15/kW $50/kW
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.

Table 2 – Wattsmart Business Demand Response Program Incentives
Participating Equipment Functionality
Wattsmart Business Demand Response
$125/kW Advanced Noticed Dispatch