20140623IPC to RNP&AWEA 1-17.pdf

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DONOVAN E. WALKER
Lead Counsel
dwal [e-mail]
June 20,2014
VIA HAND DELIVERY
Jean D. Jewel!, Secretary
ldaho Public Utilities Commission
47 2 W est Washington Street
Boise, ldaho 83702
Re: Case No. IPC-E-13-22
Update to Wind lntegration Rates and Charges - ldaho Power Company's
Response to Renewable Northwest Project and American Wind Energy
Association's First Data Request
Dear Ms. Jewell:
Enclosed for filing in the above matter are an original and three (3) copies of ldaho
Power Company's Response to Renewable Northwest Project and American Wind Energy
Association's First Data Request to ldaho Power Company.
Also enclosed are four (4) copies of a non-confidentia! disk containing information
responsive to Renewable Northwest Project and American Wind EnergyAssociation's data
requests.
Donovan E. Walker
DEW:csb
Enclosures
1221 W. ldaho St. (83702)
P.O. Box 70
Boise, lD 83707
iD,lll{.r i -::, ;--
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DONOVAN E. WALKER (lSB No. 5921)
ldaho Power Company
1221West ldaho Street (83702)
P.O. Box 70
Boise, ldaho 83707
Telephone: [phone]
Facsimile: [phone]
[e-mail]
Attorney for ldaho Power Company
!N THE MATTER OF IDAHO POWER
COMPANY'S APPLICATION TO UPDATE
ITS WIND INTEGRATION RATES AND
CHARGES.
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BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
CASE NO. IPC-E-13-22
IDAHO POWER COMPANY'S
RESPONSE TO RENEWABLE
NORTHWEST PROJECT AND
AMERICAN WIND ENERGY
ASSOCIATION'S FI RST DATA
REQUEST TO IDAHO POWER
COMPANY
COMES NOW, ldaho Power Company ("ldaho Powe/' or "Company"), and in
response to Renewable Northwest Project and American Wind Energy Association's
First Data Request to ldaho Power Company dated June 6,2014, herewith submits the
following information:
IDAHO POWER COMPANY'S RESPONSE TO RENEWABLE NORTHWEST
PROJECT AND AMERICAN WIND ENERGY ASSOCIATION'S FIRST DATA
REQUEST TO IDAHO POWER COMPANY - 1
REQUEST NO. 1: Please provide a copy of the Company's 2007 Wind
lntegration Study. (Youngblood Direct Testimony at p. 5, lines 3-18).
RESPONSE TO REQUEST NO. 1: ldaho Power's 2OO7 Wind lntegration Study
is available through its website and can be accessed via the following link:
https://www.idahopower.com/pdfs/AboutUs/PlanninoForFuture/wind/Petition ReviseAvoidedCo
stRates 1 . pdf?id=238&. pdf .
The 2007 Study Report addendum can be accessed via the following link:
https://www.idahopower.com/pdfs/AboutUs/PlanninqForFuture/wind/Addendum.pdf.
The response to this Request is sponsored by Phil DeVol, Resource Planning
Leader, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO RENEWABLE NORTHWEST
PROJECT AND AMERICAN WIND ENERGY ASSOCIATION'S FIRST DATA
REOUEST TO IDAHO POWER COMPANY - 2
REQUEST NO. 2: Please provide the underlying datasets used to prepare the
Company's 2007 and 2013 Wind lntegration Studies, including the following information:
a. Maximum generation level, minimum generation level, sta.rt-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 ldaho Power's system.
d. Scheduled and actual load data.
(DeVol Direct Testimony at p. 3, lines 7-24).
RESPONSE TO REQUEST NO. 2:
a. Please see the Excel file (Attachment 1) provided on the CD.
b. Gas plants were not included in simulations for the 2007 Wind lntegration
Study ("2007 Study"). For the 2013 Wind lntegration Study ("2013 Study") and Updated
2013 Wind lntegration Study ("Updated 2013 Study"), gas prices were respectively
$6.57lMMBtu and $S.S2lMMBtu. Market prices for the 2007 Study are provided in
Appendix F (page 85) of the 2007 Study Report (a link to the 2OO7 Study Report is
provided in the Company's response to Renewable Northwest Project ("RNP") and
American Wind Energy Association's ("AWEA") Request No. 1). Market prices for the
2013 Study and Updated 2013 Study are provided in the Company's response to RNP
and AWEA's Request No. 10.
c. Description of the analysis of 10-minute wind data for the 2007 Study is on
page 41 of the 2007 Study Report. The modeling for the 2007 Study used synthetic
wind data. The 2OOT Study synthetic wind data is provided in the Excel spreadsheets
IDAHO POWER COMPANY'S RESPONSE TO RENEWABLE NORTHWEST
PROJECT AND AMERICAN WIND ENERGY ASSOCIATION'S FIRST DATA
REQUEST TO IDAHO POWER COMPANY - 3
included on the CD: wind gen 300MW VISTA FRMT.xls (Attachment 2), wind gen
600MW VISTA FRMT.xls (Attachment 3), wind gen 900MW VISTA FRMT.xls
(Attachment 4), and wind gen 1200MW VISTA FRMT.xls (Attachment 5).
The wind data used for the 2013 Study and Updated 2013 Study modeling was
based on the average of the 100 forecasts provided by 3TIER and Energy Exemplar.
The data used in the 2013 modeling is provided in the Exce! spreadsheet included on
CD: wind data 2013 study simulations.x/sx (Attachment 6).
Other generation input to the Vista mode! used for the 2007 Study consists of
energy from Public Utility Regulatory Policies Act of 1978 ("PURPA") projects and run-
of-river hydro. The Vista model accepts inputs for energy from these sources, and
makes no dispatch decisions for these sources. Data for energy from other generation
used in the 2007 Study is provided in the Excel spreadsheet included on the CD:
other gen wind sfudies.x/sx (Attachment 7).
Other generation input to modeling for the 2013 Study and the Updated 2013
Study consists of energy from non-wind PURPA projects, run-of-river hydro, and
geothermal projects. The simulation model used for the 2013 Study and the Updated
2013 Study accepts inputs for energy from these sources, and makes no dispatch
decisions for these sources. Data for energy from other generation used in the 2013
Study is provided in the Excel spreadsheet included on the CD: other gen wind
sfudies.x/sx (Attachment 7).
d. Description of the analysis of 1O-minute load data for the 2007 Study is on
pages 40-41 of the 2007 Study Report. The modeling for the 2007 Study used actual
IDAHO POWER COMPANY'S RESPONSE TO RENEWABLE NORTHWEST
PROJECT AND AMERICAN WIND ENERGY ASSOCIATION'S FIRST DATA
REQUEST TO IDAHO POWER COMPANY - 4
load data. The actual load data used for the 2007 Study is provided in the Exce!
spreadsheet included on the CD: actual loads 2007 study.xls (Attachment 8).
The load used for the modeling for the 2013 Study was based on the projected
hourly load used in the 2011 lntegrated Resource Plan ("lRP") for the calendar year
2017. The load used for the modeling for the Updated 2013 Study was based on the
projected hourly load used in the 2013 IRP for the calendar year 2017. The load data
used for the 2013 Study and the Updated 2013 Study is provided in the Excel
spreadsheet included on the CD: /oads 2013 sfudies.x/sx (Attachment 9).
The response to this Request is sponsored by Phil DeVol, Resource Planning
Leader, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO RENEWABLE NORTHWEST
PROJECT AND AMERICAN WIND ENERGY ASSOCIATION'S FIRST DATA
REQUEST TO IDAHO POWER COMPANY - 5
REQUEST NO. 3: 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. 9-10).
RESPONSE TO REQUEST NO. 3: ldaho Power does not net the scheduling
errors for wind with the scheduling errors for other generation and load. Wind and load
are not correlated. ldaho Power calculated the correlation coefficient for wind and load
using hourly data from 2013. ldaho Power calculated the hourly change in load and the
hourly change in wind. ldaho Power then calculated the correlation coefficient for the
two time series to be 0.006 for the 2013 hourly data. The correlation coefficient is a
statistic that ranges in value from minus one to positive one where negative one
indicates that the two series are exactly inversely correlated and a value of positive one
indicates an exact correlation. Zero indicates no correlation. The calculated correlation
coefficient value of 0.006 for 2013 hourly data indicates no correlation between the
hourly change in wind generation and the hourly change in load and validates Idaho
Power's decision not to net the scheduling errors for wind with the scheduling errors for
other generation and !oad.
The response to this Request is sponsored by Phil DeVol, Resource Planning
Leader, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO RENEWABLE NORTHWEST
PROJECT AND AMERICAN WIND ENERGY ASSOCIATION'S FIRST DATA
REQUEST TO IDAHO POWER COMPANY - 6
REQUEST NO. 4: What is the Company's rationale for basing the reserve
requirement for wind on the day-ahead schedule error? (DeVol Direct Testimony at pp.
13-14,lines 8-23).
RESPONSE TO REQUEST NO. 4: As stated in the Direct Testimony of Philip B.
DeVol on pages 13-14, deviations and the required reserves are larger for the day-
ahead forecasts, but are reflective of ldaho Power dispatching and operational
decisions.
ldaho Power views the simulation of day-ahead scheduling as
appropriate due to system scheduling practices. Day-ahead
scheduling is reflective of the time frame in which Idaho Power
makes dispatching decisions and is the reasonable and prudent
time frame in which to do so. The use of day-ahead errors can be
explained by considering the implications of the alternative, where
the amount of balancing reserve is smaller because it is based on
the hour-ahead errors in forecast wind. As stated above, all
deviations between forecast and actua! wind production need to be
covered. Thus, in scheduling the system day-ahead, which is
performed for each day, the dispatchable generators would be
scheduled to carry a smaller amount of response allowing them to
cover deviations as determined from analysis of hour-ahead
forecast errors. The dispatchable generators would not be
scheduled to allow them to respond to day-ahead forecast errors,
meaning that the response to these larger errors is only achieved
by some other means, which in ldaho Powe/s view would too often
translate to a risky reliance on the wholesale electric market.
Consequently, the prudent simulation of day-ahead system
scheduling is to ensure that dispatchable generators are capable of
responding in real time to uncertainty in wind production as
determined by analysis of day-ahead forecast errors.
The response to this Request is sponsored by Phi! DeVol, Resource Planning
Leader, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO RENEWABLE NORTHWEST
PROJECT AND AMERICAN WIND ENERGY ASSOCIATION'S FIRST DATA
REQUEST TO IDAHO POWER COMPANY - 7
REQUEST NO. 5: Please provide 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 reserve requirements for wind on
the hour-ahead schedule error?
(DeVol Direct Testimony at pp. 13-14,lines 8-23).
RESPONSE TO REQUEST NO. 5: ldaho Power generally followed the
procedures described in the publication, The Evolution of Wind Power lntegration
Sfudies; Past, Present, and Future., Ela, E.; Milligan, M.; Parsons, B.; Lew, D.; Corbus,
D., Power and Energy Society General Meeting, 2009 IEEE, pages 1-8. Available at:
http://ieeexplore.ieee.orq/xpl/looin.isp?tp=&arnumber=5275981&url=http%3A%2F%2Fieeexplor
e.ieee.ors%2Fiel5o/o2F5230481%2F5260217o/o2F05275981.odfo/o3Farnumbeflo3D5275981.
The IEEE authors note on page 4 that utility simulation analyses "represent the
idea that a utility will make unit commitment decisions well in advance of real-time,
based on wind forecasts and load forecasts, and will make additional decisions when
correcting dispatch in real-time given the origina! commitment set." Consistent with the
IEEE publication, ldaho Power makes unit commitment decisions in the day-ahead
market. ldaho Power based the reserve requirement decisions for wind on the wind
forecast day-ahead schedule error.
The response to this Request is sponsored by Phil DeVol, Resource Planning
Leader, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO RENEWABLE NORTHWEST
PROJECT AND AMERICAN WIND ENERGY ASSOCIATION'S FIRST DATA
REQUEST TO IDAHO POWER COMPANY - 8
REQUEST NO. 6: 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? lf 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. 13-14,lines 8-23).
RESPONSE TO REQUEST NO. 6: ldaho Power has not performed any
analyses of reserve requirements for wind using hour-ahead schedule error.
The response to this Request is sponsored by Phil DeVol, Resource Planning
Leader, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO RENEWABLE NORTHWEST
PROJECT AND AMERICAN WIND ENERGY ASSOCIATION'S FIRST DATA
REQUEST TO IDAHO POWER COMPANY - 9
REQUEST NO. 7: 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 efficiently 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 lnterchange?
e. Has the Company used or analyzed the costs and benefits of using
a recallable energy product as a source of reg-up reserves?
f. Has the Company analyzed the costs and benefits of joining the
CAISO-PacifiCorp Energy lmbalance Market in 2015?
(Youngblood Direct Testimony at pp. 4-12; DeVol Direct Testimony at pp. 12-13,lines 3-
7).
RESPONSE TO REQUEST NO. 7:
a. ldaho Power has adopted a wind forecasting tool which has improved
forecasting accuracy of wind generation on both the day-ahead and hourly forecast
basis.
b. The Company schedules energy into and out of ldaho Poweds system as
market and demand conditions warrant. Currently, although there are tools available to
IDAHO POWER COMPANY'S RESPONSE TO RENEWABLE NORTHWEST
PROJECT AND AMERICAN WIND ENERGY ASSOCIATION'S FIRST DATA
REQUEST TO IDAHO POWER COMPANY - 1O
schedule energy intra-hour, there is insufficient market liquidity for intra-hour market
products at this time.
The Company utilizes pricing to determine whether to procure energy from
the market. Because of transmission constraints and the requirement to have firm
transmission to support balancing types of transactions, the Company has not pursued
balancing reserves from the market.
d. The Company participates in the ACE Diversity lnterchange ("ADl") and
was one of the founding members for ADI.
e. The Company has utilized non-firm energy products as a source of reg-up
reserves. These energy products result in a discounted price from standard energy
products and are considered based on energy prices and the available energy
resources within the Balancing Area.
f . The Company has not analyzed the benefits of joining the California
Independent System Operator (CAISO) energy imbalance market (ElM) in 2015,
primarily because the Company does not have firm transmission rights to access the
California market.
The response to this Request is sponsored by Tessia Park, Load Serving
Operations Director, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO RENEWABLE NORTHWEST
PROJECT AND AMERICAN WIND ENERGY ASSOCIATION'S FIRST DATA
REQUEST TO IDAHO POWER COMPANY - 11
REQUEST NO. 8: Please provide the rationale for charging new QFs for the
"under collection from existing wind QFs." (Youngblood Direct Testimony at p. 12, lines
8-13).
RESPONSE TO REQUEST NO. 8: The federal regulations define avoided costs
as "the incremental costs to an electric utility of electric energy or capacity or both
which, but for the purchase from a qualifying facility or qualifying facilities, such utility
would generate itself or purchase from another source." 18 C.F.R S 292.101(b) (6). ln
essence, the Company's customers should remain indifferent from a cost perspective to
the addition of PURPA qualifying facility ('QF") generation as compared to other
generation sources.
As outlined in testimony (Youngblood Direct Testimony, pp. 1 1-23), the Company
discussed three separate methods, from which the ldaho Public Utilities Commission
("Commission") could choose to implement, to account for wind integration costs in
avoided cost rates. Because the existing wind PURPA contracts have the costs
associated with wind integration assessed on a percentage basis of various avoided
cost rates, or have no assessment of wind integration costs at all, the actual cost of
integration is not being fully recovered from the existing PURPA contracts.
Consequently, the difference between the integration costs assessed to QFs and the
actua! integration costs incurred are being recovered through customer rates.
The Company's wind integration study concluded that the marginal cost of
integrating wind generation increases as the penetration of the wind generation on the
Company's system increases. The "rationale" for charging new QFs for the under
collection from existing wind QFs is simply to ensure that retail customers remain
IDAHO POWER COMPANY'S RESPONSE TO RENEWABLE NORTHWEST
PROJECT AND AMERICAN WIND ENERGY ASSOCIATION'S FIRST DATA
REQUEST TO IDAHO POWER COMPANY - 12
indifferent to the addition of PURPA QF generation. The Company proposed this
allocation of the under collection amount on the first two of the three methods proposed
for the Commission's consideration.
The response to this Request is sponsored by Michael J. Youngblood,
Regulatory Project Manager, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO RENEWABLE NORTHWEST
PROJECT AND AMERICAN WIND ENERGY ASSOCIATION'S FIRST DATA
REQUEST TO IDAHO POWER COMPANY - 13
REQUEST NO. 9: Please clarify whether the data developed by 3Tier for the
2013 Wind lntegration Study includes any actualwind generation data from projects that
are currently operational, or whether it is all synthetic data based on the locations of
potential future wind projects. lf 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 at p. 15, lines 1-25).
RESPONSE TO REQUEST NO. 9: Synthetic wind data, as opposed to actual
wind data, was used because actual forecasts were not available for existing projects at
the time and the synthetic data was the best data available for use in the study. The
data developed by 3Tier for the 2013 Wind lntegration Study does not include wind
generation data from operating wind projects. ldaho Power contracted with Energy
Exemplar, who contracted with 3Tier, to develop the forecast data set to use in the 2013
Study. As identified in Mr. DeVol's testimony on page 15,3TIER developed the
synthetic wind data and the forecast time series directly from the WWSIS data set for 43
locations identified by Idaho Power. The 43 locations correspond to project sites that
either have a current contract or have requested a contract with ldaho Power.
The response to this Request is sponsored by Phil DeVol, Resource Planning
Leader, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO RENEWABLE NORTHWEST
PROJECT AND AMERICAN WIND ENERGY ASSOCIATION'S FIRST DATA
REQUEST TO IDAHO POWER COMPANY - 14
REQUEST NO. 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 Powe/s hydro resources in order to make the capacity available for
integrating wind. (DeVol Direct Testimony at p. 17, lines 3-22).
RESPONSE TO REQUEST NO. 10: The study assumed Mid-Columbia trading
hub wholesale prices as projected for 2017 from the 2011 IRP for the 2013 Study and
from the 2013lRP forthe Updated 2013 Study. The Mid-Columbia prices are listed in
the Excel spreadsheets provided on the CD.
The response to this Request is sponsored by Phil DeVol, Resource Planning
Leader, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO RENEWABLE NORTHWEST
PROJECT AND AMERICAN WIND ENERGYASSOCIATION'S FIRST DATA
REQUEST TO IDAHO POWER COMPANY - 15
REQUEST NO. 11: Please provide the Company's analysis supporting the
statement that "at times even the regional market wil! be insufficient to integrate wind."
Please describe at what times and under what conditions the regional market would be
insufficient to integrate wind. (Exhibit 1 to DeVol Direct Testimony, Wind lntegration
Study Report, al l7).
RESPONSE TO REQUEST NO. 11 : Page 34 of the 2013 Study states:
Modeling performed for the wind study has demonstrated the
occurrence during low load periods where the balancing reserves
necessary for responding to a wind up-ramp (i.e., generation that
can be dispatched down in response to an increase in wind) cannot
be provided without pushing the system to an overgeneration
condition. Customer load for these periods, where load consists of
sales to retail customers and to wholesale customers by way of
regional transmission connections, is too low to allow for the
integration of a significant quantity of wind. This situation requires
curtailment of wind generation to maintain system balance. For the
wind study modeling, the curtailed wind generation was removed
from the production cost analysis and consequently did not affect
the calculated integration cost. Curtailed wind was not integrated in
the modeling and had no influence on the calculated integration
costs. Not surprisingly, curtailment was found in the wind study
modeling to have a strong correlation with customer load, water
condition, and wind penetration levels.
The response to this Request is sponsored by Phil DeVol, Resource Planning
Leader, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO RENEWABLE NORTHWEST
PROJECT AND AMERICAN WIND ENERGY ASSOCIATION'S FIRST DATA
REQUEST TO IDAHO POWER COMPANY.l6
REQUEST NO. 12: ls it the Company's understanding that there is a
requirement that wind be traded over dynamic tags? lf so, please provide the citation to
such requirement and the conditions under which it would apply. (Exhibit 1 to DeVol
Direct Testimony, Wind lntegration Study Report, at 19).
RESPONSE TO REQUEST NO. 12: lt is not a specific requirement that wind be
traded using dynamic tags; however, if wind generation was block scheduled on an
E-Tag, it would require firming of those resources by the source balancing area and
ldaho Power's Open Access Transmission Tariff (OATT), which contains the required
services applicable to that generator. Dynamic tags are the mechanism utilized to
transfer the variability of the wind resource to the sink Balancing Area, which would
relieve the source Balancing Area of the requirement to firm that resource.
The response to this Request is sponsored by Tessia Park, Load Serving
Operations Director, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO RENEWABLE NORTHWEST
PROJECT AND AMERICAN WIND ENERGY ASSOCIATION'S FIRST DATA
REQUEST TO IDAHO POWER COMPANY - 17
REQUEST NO. 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 statistica! measure
of the balancing reserve needs over the given month? (Exhibit 1 to DeVol Direct
Testimony, Wind Integration Study Report, at24).
RESPONSE TO REQUEST NO. 13: Page 24 of the 2013 Study states:
The monthly requirements for balancing reserves are given in Table
5 for the wind penetration levels studied. The term Reg Up is used
for generating capacity that can be brought online in response to a
drop in wind relative to the forecast. Reg Down is used for online
generating capacity that can be turned down in response to a wind
up-ramp.
ln addition, page 23 of the 2013 Study states:
The balancing reserves requirements were calculated as the bi
directional capacity covering 90 percent of the deviations. The use
of the 90 percent confidence level for the wind integration analysisis consistent with the criterion used for hydro conditions in
assessing peak-hour resource adequacy in integrated resource
planning.
The values reported in Table 5 were used in ldaho Power's system simulation to
estimate the wind integration costs.
The response to this Request is sponsored by Phil DeVol, Resource Planning
Leader, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO RENEWABLE NORTHWEST
PROJECT AND AMERICAN WIND ENERGY ASSOCIATION'S FIRST DATA
REQUEST TO IDAHO POWER COMPANY. 18
REQUEST NO. 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, diurnally, or other? Please provide the reserve requirement
figures in the form that they were inputted into the system simulation model. (Exhibit 1
to DeVol Direct Testimony, Wind lntegration Study Report, at24).
RESPONSE TO REQUEST NO. 14: Wind-caused balancing reserves are
provided in Table 5 on page 25 of the 2013 Study. Please see the Company's
response to RNP and AWEA's Request No. 13. The balancing reserves are input into
the system simulation model on an hourly basis. The amount of balancing reserves
input into the simulation model for a given operating hour depends on the month and
the projected level of wind production input into the simulation model. The amount of
balancing reserves input into the simulation model for a given operating hour is a
function of month and projected level of wind production, but does not exceed the
amounts of Table 5. The reserve requirement figures in the form they were input into
the system simulation model are listed in the Exce! spreadsheet provided on the CD.
The response to this Request is sponsored by Phil DeVol, Resource Planning
Leader, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO RENEWABLE NORTHWEST
PROJECT AND AMERICAN WIND ENERGY ASSOCIATION'S FIRST DATA
REQUEST TO IDAHO POWER COMPANY - 19
REQUEST NO. 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. ls 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 1 to DeVol Direct Testimony, Wind lntegration Study Report, at25).
RESPONSE TO REQUEST NO. 15: The model uses a forecast demand for
each hour in a 168-hour (one week) period and simultaneously optimizes generation
scheduling for the entire period. ln this model, this "balancing reserve requirement" for
system demand provides capacity for several uncertainties, ranging from: load forecast
error, in-hour load following requirements, and regulation requirements. To reserve
capacity for these requirements, 3 percent was used.
ln Idaho Powe/s modeling, each uncertainty has different but overlapping time
frames: load forecast errors are assumed to begin day-ahead and extend into realtime,
load following varies hour to hour, and load regulation varies minute to minute. The 3
percent level of reserve is viewed as a reasonable level in capturing these uncertainties,
but there is not, in a strict sense, an analogous reserve quantity carried in practice for
comparison. The balancing reserve requirement imposed for demand is input in an
effort to simulate system operations as realistically as possible.
ln the 2013 Study, the balancing reserve requirement for demand is imposed at
the same level in all simulations, whether a test case for which wind-caused reserve is
IDAHO POWER COMPANY'S RESPONSE TO RENEWABLE NORTHWEST
PROJECT AND AMERICAN WIND ENERGY ASSOCIATION'S FIRST DATA
REQUEST TO IDAHO POWER COMPANY - 20
necessary or a base case with no wind-caused reserve, and therefore is not considered
to substantially influence production cost differences between the test case and base
case.
The response to this Request is sponsored by Phil DeVo!, Resource Planning
Leader, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO RENEWABLE NORTHWEST
PROJECT AND AMERICAN WIND ENERGY ASSOCIATION'S FIRST DATA
REQUEST TO IDAHO POWER COMPANY - 21
REQUEST NO. 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 OctobeP (Exhibit 1 to DeVol Direct Testimony, Wind
lntegration Study Report, at28).
RESPONSE TO REQUEST NO. 16: The Federa! Energy Regulatory
Commission places restrictions on transmission provide/s native load (retail customers)
ability to hold transmission capacity in excess of its needs. To model these limitations,
net firm purchases from the market are limited on a monthly basis to only the capacity
and energy required to serve ldaho Power's retail load.
The response to this Request is sponsored by Phil DeVol, Resource Planning
Leader, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO RENEWABLE NORTHWEST
PROJECT AND AMERICAN WIND ENERGY ASSOCIATION'S FIRST DATA
REQUEST TO IDAHO POWER COMPANY - 22
REQUEST NO. 17: Please provide the basis for assessing a $50/MWh penalty
on non-firm imports. (Exhibit 1 to DeVol Direct Testimony, Wind lntegration Study
Report, at 28).
RESPONSE TO REQUEST NO. 17: In the simulations, the prefened source to
serve firm load is a firm purchase and for the firm purchase to fit within the firm
transmission import capability. Without a price penalty on non-firm purchases, the
model would over utilize non-firm energy, which overstates transmission access
available to ldaho Power. The penalty price is also necessary to ensure firm load is
served with dispatchable firm generation before non-firm energy.
The response to this Request is sponsored by Phil DeVol, Resource Planning
Leader, ldaho Power Company.
DATED at Boise, ldaho, this 20th day of June 20'14.M
DONOVAN E. WALKER
Attorney for ldaho Power Company
IDAHO POWER COMPANY'S RESPONSE TO RENEWABLE NORTHWEST
PROJECT AND AMERICAN WIND ENERGY ASSOCIATION'S FIRST DATA
REQUEST TO IDAHO POWER COMPANY - 23
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 20th day of June 2014 ! served a true and
conect copy of IDAHO POWER COMPANY'S RESPONSE TO RENEWABLE
NORTHWEST PROJECT AND AMERICAN WIND ENERGY ASSOCIATION'S FIRST
DATA REQUEST TO IDAHO POWER COMPANY upon the following named parties by
the method indicated below, and addressed to the following:
Commission Staff
Kristine A. Sasser
DepUty Attomey General
ldaho Public Utilities Commission
47 2 W est Washington (83702)
P.O. Box 83720
Boise, ldaho 83720-007 4
ldaho Winds LLC
Dean J. Miller
McDEVITT & MILLER LLP
420 West Bannock Street (83702)
P.O. Box 2564-83701
Boise, ldaho 83701
Rick Koebbe, President
ldaho Winds LLC
5420 West Wicher Road
Glenns Ferry, ldaho 83623
Bob Eggers, Legal Counsel
ldaho Winds, LLC
15850 Jess Ranch Road
Tracy, California 95377
Cold Springs Windfarm, LLC; Desert
Meadow Windfarm, LLC; Hammett Hill
Windfarm, LLC; Mainline Windfarm, LLC;
Ryegrass Windfarm, LLG; and Two Ponds
Windfarm, LLC
Peter J. Richardson
RICHARDSON ADAMS, PLLC
515 North 27th Street
Boise, ldaho 83702
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IDAHO POWER COMPANY'S RESPONSE TO RENEWABLE NORTHWEST
PROJECT AND AMERICAN WIND ENERGY ASSOCIATION'S FIRST DATA
REQUEST TO IDAHO POWER COMPANY - 24
Benjamin G. Huang, Manager
c/o Mountain Air Projects
6000 North Foxtail Way
Glenns Ferry, ldaho 83623
Cassia Wind Farm LLG; Hot Springs
Windfarm, LLC; Bennett Creek Windfarm,
LLC; Gassia Gulch Wind Park LLG; Tuana
Springs Energy, LLG; and High Mesa
Energy, LLC
Gregory M. Adams
RICHARDSON ADAMS, PLLC
515 North 27th Street
Boise, ldaho 83702
Paul Ackerman
Assistant General Counsel
Exelon Business Services Corporation
100 Constellation Way
Baltimore, Maryland 21202
American Wind Energy Association and
Renewable Northwest Project
Teresa A. Hil!
K&L GATES, LLP
One S.W. Columbia Street, Suite 1900
Portland, Oregon 97258
Dina M. Dubson
Renewable Northwest Project
421 SW 6th Avenue, Suite 1125
Portland, Oregon 97204
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IDAHO POWER COMPANY'S RESPONSE TO RENEWABLE NORTHWEST
PROJECT AND AMERICAN WIND ENERGY ASSOCIATION'S FIRST DATA
REQUEST TO IDAHO POWER COMPANY - 25