20140606RNP and American Wind Energy 1-17 to IPC.pdf

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ISB No. 6175
K&L Gates LLP
One Columbia St. Suite 1900
Portland, OR 97258
Telephone: [phone]
Fax: [phone]
Attorneyfor Renewoble Northwest Project and American Wind Energy Association
BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
TN THE MATTER OF THE
APPLICATION OF IDAHO POWER
COMPANY TO UPDATE ITS WTND
INTEGRATION RATES AND
CHARGES.
Case No. IPC-E-13-22
Renewable Northwest Project and American
Wind Energy Association's First Data Request
to Idaho Power Company
l.Please provide a copy of the Company's 2007 Wind Integration Study. (Youngblood
Direct Testimony at p. 5, lines 3-18).
Please provide the underlying datasets used to prepare the Company's2007 and2013
Wind Integration Studies, including the following information:
a. Maximum generation level, minimum generation level, start-up time, and ramp
rates for all resources on the Company's system.
b. Gas price and market price forecasts used in the studies.c. Scheduled and actual generation data for wind and all other generation on Idaho
Power's system.
d. Scheduled and actual load data.
(DeVol Direct Testimony at p. 3,lines 7 -24).
When calculating the incremental reserve requirement for integrating wind generation,
does the Company net the scheduling errors for wind with the scheduling errors for other
generation and load? Please explain why or why not. (DeVol Direct Testimony at pp. 9-
l0).
What is the Company's rationale for basing the reserve requirement for wind on the day-
ahead schedule error? (DeVol Direct Testimony at pp. l3-14, lines 8-23).
Renewable Northwest Project and American Wind Energy Association's First Data Request
to Idaho Power Company
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2.
3.
4.
Please provide all wind integration studies that you relied upon in making your decision
to base your reserve requirements for wind on the day-ahead schedule error.
a. Which of these studies base their reserve requirements for wind on the day-ahead
schedule error?
b. Which of these studies base their reserye requirements for wind on the hour-ahead
schedule error?
(DeVol Direct Testimony atpp.13-14, lines 8-23).
Has the Company performed any analysis of what the reserve requirements would be for
wind using hour-ahead schedule error instead of day-ahead schedule error? If so, what
would the minimum, maximum, and average incremental reserve requirements be for
wind if the Company were to base the requirement on hour-ahead schedule error using
30-minute persistence? (DeVol Direct Testimony at pp. l3-14, lines 8-23).
Since the Company first began assessing an integration charge on wind generator QFs in
2007, what operational tools has the Company implemented in order to integrate wind
generation more effi ciently and cost-effectively?
a. Has the Company adopted measures to improve its forecasting capability?
b. Has the Company scheduled its own off-system sales on an intra-hour basis?c. Has the Company procured or sought to procure more cost-effective sources of
balancing reserves from third parties?
d. Has the Company participated in the ACE Diversity Interchange?
e. Has the Company used or analyzed the costs and benefits of using a recallable
energy product as a source ofreg-up reserves?f. Has the Company analyzed the costs and benefits ofjoining the CAISO-
PacifiCorp Energy Imbalance Market in 2015?
(Youngblood Direct Testimony atpp.4-12; DeVol Direct Testimony atpp.12-13, lines
3-7).
8. Please provide the rationale for charging new QFs for the "under collection from existing
wind QFs." (Youngblood Direct Testimony atp.12,lines 8-13).
9. Please clarify whether the data developed by 3Tier for the 2013 Wind Integration Study
includes any actual wind generation data from projects that are currently operational, or
whether it is all synthetic data based on the locations of potential future wind projects. If
the latter is correct, please explain the Company's rationale for using synthetic wind data
instead of actual wind generation data from existing projects. (DeVol Direct Testimony
atp. 15, lines l-25).
10. Please provide the market price assumptions the Company relied upon in arriving at the
Company's opportunity costs of holding generating capacity from Idaho Power's hydro
resources in order to make the capacity available for integrating wind. (DeVol Direct
Testimony at p. 17, lines 3-22).
Renewable Northwest Project and American Wind Energy Association's
First Data Request to Idaho Power Company
5.
6.
7.
I L Please provide the Company's analysis supporting the statement that "at times even the
regional market will be insufficient to integrate wind." Please describe at what times and
under what conditions the regional market would be insufficient to integrate wind.
(Exhibit I to DeVol Direct Testimony, Wind Integration Study Report, at 17).
12. Is it the Company's understanding that there is a requirement that wind be traded over
dynamic tags? If so, please provide the citation to such requirement and the conditions
under which it would apply. (Exhibit I to DeVol Direct Testimony, Wind Integration
Study Report, at l9).
13. For the balancing reserve requirements listed in Table 5, are these monthly balancing
reserve requirements the maximum, minimum, or average balancing reserve
requirements, or does the table reflect some other statistical measure of the balancing
reserve needs over the given month? (Exhibit I to Devol Direct Testimony, Wind
Integration Study Report, at24).
14. Which balancing reserve requirement figure is input into the Company's system
simulation model-the maximum, average, or some other figure? On what time scale is
the reserve requirement inputted into the system simulation model-hourly, monthly,
diumally, or other? Please provide the reserve requirement figures in the form that they
were inputted into the system simulation model. (Exhibit I to Devol Direct Testimony,
Wind Integration Study Report, at24).
15. Please provide all work papers, data, and analysis supporting the use of a "balancing
reserve requirement equal to 3 percent of the system demand as capacity reserved to
allow for variability and uncertainty in load."
a. Is this calculation based on observed real-time system demand or forecast system
demand?
b. If based on forecast system demand, how far in advance is the forecast for
demand-hour-ahead, day-ahead, or some other timeframe?
(Exhibit I to DeVol Direct Testimony, Wind Integration Study Report, at25).
16. Please provide the basis for the transmission constraint figures used in Table 6. What
constraints are driving the significant reductions in February, March, April and October?
(Exhibit I to Devol Direct Testimony, Wind Integration Study Report, at28).
17. Please provide the basis for assessing a $50/NdWh penalty on non-firm imports. (Exhibit
I to DeVol Direct Testimony, Wind Integration Study Report, at28).
Renewable Northwest Project and American Wind Energy Association's
First Data Request to Idaho Power Company
DATED this 6th day of June, 2014
K&L Gates LLP
Renewable Northwest Project and American Wind Energy Association's
First Data Requestto Idaho Power Company
Attorney for RNP and AWEA
CERTIFICATE OF SERVICE
I hereby certify that on the 6th day of June,2014, a true and correct copy of the foregoing
RENEWABLE NORTHWEST PROJECT AND AMERICAN WTND ENERGY
ASSOCIATION'S FIRST DATA REQUEST TO IDAHO POWER COMPANY, Case No. IPC-
E-13-22, was served by electronic mail to:
IDAHO POWER COMPANY:
COMMISSION STAFF:
IDAHO WINDS LLC:
Donovan E. Walker
Idaho Power Company
l22lW. Idaho St. (83702)
P.O. Box 70
Boise,ID 83707-0070
Email : dr,va [e-mail]
doc kets@. idahopow'cr.conr
Michael J. Youngblood
Greg Said
Idaho Power Company
l22lW. Idaho St. (83702)
P.O. Box 70
Boise,ID 83707-0070
Email: myoungblood@idahopow'er.com
gsa id@ idahoporver.conr
Kris Sasser
Deputy Attorney General
Idaho Public Utilities Commission
47 2 W . Washington (837 02)
P.O. Box 83720
Boise,lD 83720-0074
Email : kris.sasserl0puc.idaho. gov
Dean J. Miller
McDevitt & Miller LLP
420 W. Bannock Street
Boise, ID 83702
Email : ioe@)mcdev itt-mi I ler.com
Rick Koebbe, President
Idaho Winds, LLC
5420W.WicherRoad
Glenns Ferry, ID 83623
Renewable Northwest Project and American Wind Energy Association's
First Data Request to Idaho Power Company
COLD SPRINGS WINDFARM, LLC;
DESERT MEADOW WINDFARM, LLC;
HAMMETT HILL WINDFARM, LLC;
MAINLINE WINDFARM, LLC;
RYEGRASS WINDFARM, LLC; AIYD
TWO PONDS WINDFARM, LLC:
CASSIA WINDFARM LLC;
HOT SPRINGS WINDFARM LLC;
BEI\INETT CREEK WINDFAR]VI LLC;
CASSIA GT]LCH WIND PARK LLC;
TUANA SPRINGS ENERGY, LLC; AND
HIGH MESA EI\'ERGY, LLC:
Email: [e-mail]
Bob Eggers, Legal Counsel
Idaho Winds, LLC
Email: [e-mail]
Peter J. Richardson
Richardson Adams, PLLC
515 N. 27th Street
Boise, ID 83702
Emai I : [e-mail]
Benjamin G. Huang, Manager
c/o Mountain Air Projects
6000 N. Foxtail Way
Glenns Ferry, ID 83623
Gregory M. Adams
Richardson Adams, PLLC
515 N. 27th Street
Boise, lD 83702
Emai I : [e-mail]
Paul Ackerman
Assistant General Counsel
Exelon Business Services Corporation
100 Constellation Way
Baltimore, MDZl202
DATED this 6th day of June,2014.
Renewable Northwest Project and American Wind Energy Association's
First Data Request to Idaho Power Company
K&L GATES LLP