20230223Comments.pdf

BAYER’S INITIAL COMMENTS 1
Thomas J. Budge, ISB No. 7465 RACINE OLSON, PLLP
P.O. Box 1391; 201 E. Center
Pocatello, Idaho 83204-1391 Telephone: [phone] Fax: [phone] [e-mail]
Attorney for P4 Production, L.L.C., an affiliate of Bayer Corporation BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION

IN THE MATTER OF THE APPLICATION
OF ROCKY MOUNTAIN POWER FOR AUTHORITY TO IMPLEMENT A COMMERCIAL AND INDUSTRIAL DEMAND RESPONSE PROGRAM
CASE NO. PAC-E-22-13 BAYER’S INITIAL COMMENTS
P4 Production, L.L.C., an affiliate of Bayer Corporation (referred to herein as “Bayer”),
submits the following comments pursuant to the Commission’s Notice of Amended Comment
Deadlines entered January 11, 2023, in this matter.
Background
On August 25, 2022, Rocky Mountain Power, a division of PacifiCorp (the “Company”)
filed an Application with the Commission requesting authority to implement a Class 1
commercial and industrial demand response program (“Wattsmart Business Demand Response”
or “Program”) under the existing Schedule 114. Bayer filed a petition to intervene on October
31, 2022, which was granted by Order No. 35598 entered November 17, 2022.
Comments
1. Bayer does not oppose the Wattsmart Business Demand Response Program. Cost-
effective demand response programs should reduce the need for additional capacity and should
also reduce costs to ratepayers.
2. The Company’s Application states that the Program would apply to customers
“with curtailable loads greater than 500 kW that can be curtailed with no advance notice or
limited advance notice (7-minutes).” (Application, p. 2, ¶ 4.) According to the Company, there
are 36 customers in Idaho with a load of 500 KW, and an additional 28 customers with an
RECEIVED
Thursday, February 23, 2023 10:37:54 AM
IDAHO PUBLIC
UTILITIES COMMISSION
BAYER’S INITIAL COMMENTS 2
“aggregate load” of 500KW. From the Company’s filing, it is not clear how load aggregation
would be effective considering the coordinated response time needed for different load locations.
Bayer recommends that the Commission require additional information concerning this issue.
3. The Company initially proposes a 15 MW load eligibility requirement, with the
option to add additional MW into the Program. Bayer would not oppose additional MW if
deemed cost-effective.
4. The Company currently charges a 2.5% adder to customers’ bills for the
Customer Efficiency Rate Adjustment. This adjustment clause (Schedule No. 191) is the vehicle
under which the Company proposes to collect the budgeted costs of the Program. Bayer
recommends that these charges be monitored by the Commission to ensure they are just and
reasonable.
5. If the Program is expanded in Idaho and eventually other Company jurisdictions,
such expansion should be evaluated for cost-effectiveness in relation to the economic and
operating value of existing demand response products already being provided, including those
under current special contracts.

DATED this 23rd day of February, 2023.

RACINE OLSON, PLLP
By: ___________________________ THOMAS J. BUDGE

BAYER’S INITIAL COMMENTS 3
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this 23rd day of February, 2023, I served a true, correct and
complete copy of the foregoing document by email to each of the following:
Idaho Public Utilities Commission
P.O. Box 83720 Boise, ID 83720-0074 [e-mail]
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
[e-mail]
Michael S. 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
825 NE Multnomah Street, Suite 2000
Portland, OR 97232 [e-mail]
PacifiCorp [e-mail] Attorney for Idaho Irrigation Pumpers Association, Inc. ECHO HAWK & OLSEN, PLLC
505 Pershing Ave., Ste. 100
P.O. Box 6119 Pocatello, Idaho 83205 [e-mail]
Idaho Irrigation Pumpers Association, Inc. 2623 NW Bluebell Place Corvallis, OR 97330 [e-mail]
Brian C. Collins Greg Meyer Bayer Corporation 16690 Swingley Ridge Rd., #140
Chesterfield, MO 63017
[e-mail]

THOMAS J. BUDGE