20140715Staff 1-10 to AWEA&RNP.pdf

KRTSTINEA. SASSER nfiCIEfl'rri;
DEPUTY ATTORNEY GENERAL
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PO BOX 83720 IDAHC irl;L ,r.lBOISE,IDAHO 83720-0074 UTILITIES C0[lMlS$lr]ii
(208) 334-03s7
BAR NO. 6618
Street Address for Express Mail:
472W. WASHINGTON
BOISE, IDAHO 83702-5918
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF IDAHO POWER
COMPANY'S APPLTCATION TO UPDATE ITS ) CASE NO. IPC-E-13-22
WIND INTEGRATION RATES AND CHARGES. )) FIRST PRODUCTION
) REQUEST OF THE) coMMrssroN STAFF To
) AWEA AND RENEWABLE
) NORTHWEST
The Staff of the Idaho Public Utilities Commission, by and through its attomey of record,
Kristine A. Sasser, Deputy Attorney General, requests that Idaho Power Company (Company)
provide the following documents and information on or before TUESDAY, AUGUST 5,2014.
This Production Request is to be considered as continuing, and Idaho Power Company is
requested to provide, by way of supplementary responses, additional documents that it or any person
acting on its behalf may later obtain that will augment the documents produced.
Please provide answers to each question and any supporting workpapers that provide detail or
are the source of information used in calculations. The Company is reminded that responses pursuant
to Commission Rules of Procedure must include the name and phone number of the person preparing
the document, and the name, location and phone number of the record holder and, if different, the
witness who can sponsor the answer at hearing. Reference IDAPA 31.01.01.228.
FIRST PRODUCTION REQUEST
TO AWEA AND RENEWABLE
NORTHWEST JULY 15,2OI4
In addition to the written copies provided as response to the questions, please provide all
Excel and electronic files on CD with formulas activated.
REQUEST NO. 1: Please provide a copy of all spreadsheets, workpapers, analysis,
calculations and other documentation used or relied upon to derive the recommended integration cost
of $5.84/MWh as presented on page 19 of AWEA and Renewable Northwest's comments.
REQUEST NO. 2: Please provide a copy of all spreadsheets, workpapers, analysis,
calculations and other documentation used or relied upon to derive the recommended integration cost
of $5.30/MWh as presented on page 19 of AWEA and Renewable Northwest's comments.
REQUEST NO. 3: AWEA and Renewable Northwest's comments state on page 19
"However, our calculations are based in part on limited data from Idaho Power, and more analysis
may be required to arrive at accurate wind integration rates." Please describe the additional data and
analysis that you believe you need to arrive at accurate wind integration rates. Has AWEA and
Renewable Northwest requested the additional data from Idaho Power? Does AWEA and Renewable
Northwest intend to request the additional data and perform additional analysis?
REQUEST NO. 4: AWEA and Renewable Northwest's comments explain the netting
concept in an example presented on pages 11-12 in which load forecast error is + 10 MW and wind
forecast error is -13 MW. In the example, AWEA and Renewable Northwest contend that wind and
load error cancel each other out and that the system operator only needs to dispatch 3 MW of
balancing reserves. Is it equally probable that the wind and load forecast errors could both be either
positive or negative, therefore not cancel each other out? If so, would the reserve requirement be
equal to 23 MW? Why wouldn't the appropriate reserye requirement be equal to the square root of
the sum of the squares (16.4 MW) as discussed on pages 12 -13?
REQUEST NO. 5: Please discuss whether AWEA and Renewable Northwest believe that
Idaho Power incurs additional costs due to day-ahead wind forecast errors. If so, how would these
costs be captured using the hour-ahead forecasting approach advocated by AWEA and Renewable
Northwest?
FIRST PRODUCTION REQUEST
TO AWEA AND RENEWABLE
NORTHWEST 2 JULY I5,2OI4
REQUEST NO. 6: Does AWEA and Renewable Northwest believe there could be costs
associated with both hour-ahead and day-ahead forecasting errors?
REQUEST NO. 7: On page 9 of AWEA and Renewable Northwest's comments it states "As
the wind comes up, a utility will back off more expensive generation previously made available in the
day-ahead time frame to meet load, which saves the utility operating costs. As the wind drops off, a
utility will increase the use of its more expensive generation, hour-by-hour, adjusting for the wind's
output and mindful to not use any more higher-cost generation than necessary." If both the utility's
day-ahead and hour-ahead wind forecasts were perfectly accurate, but the utility still had to back
down more expensive generation resources in order to receive wind generation (or alternatively, less
expensive resources), would AWEA and Renewable Northwest consider these to be integration costs?
How would these costs be captured by the utility if they are not considered integration costs? Does
AWEA and Renewable Northwest believe these costs would be captured by a wind integration study
performed using Idaho Power's method or the method recommended by AWEA and Renewable
Northwest? Does AWEA and Renewable Northwest believe these costs are captured in either the
SAR or IRP methodologies employed by the Commission for calculating avoided cost rates?
REQUEST NO. 8: Please provide a list of AWEA and Renewable Northwest's members in
Idaho.
REQUEST NO.9: Please describe AWEA and Renewable Northwest's participation, either
in person or by phone, in any advisory committee meetings, public meetings or workshops conducted
by Idaho Power relating to the 2013 Wind Study.
REQUEST NO. 10: Please provide a copy of all written comments, notes, memoranda or
other documentation directly related to any critique, concerns, or recommendations made by AWEA
or Renewable Northwest on the draft of Idaho Power's 2013 Wind Study.
FIRST PRODUCTION REQUEST
TO AWEA AND RENEWABLE
NORTHWEST JULY 15,2OI4
Dated at Boise, Idaho, this 1b4", of July 2014.
Technical Staffl Rick Sterling
i:umisc:prodre{ipccl3.22lsrps prod req I
FIRST PRODUCTION REQUEST
TO AWEA AI{D RENEWABLE
NORTHIfiTEST JULY 15,2014
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 15th DAY OF JULY 2074,
SERVED THE FOREGOING FIRST PRODUCTION RE,QUEST OF THE
COMMISSION STAFF TO AWEA AND RENEWABLE NORTHWEST, IN CASE
NO. IPC-E-13-22, BY MAILING A COPY THEREOF, POSTAGE PREPAID, TO THE
FOLLOWING:
DONOVAN E WALKER
REGULATORY DOCKETS
IDAHO POWER COMPANY
PO BOX 70
BOISE rD 83707-0070
E-MAIL: [e-mail]
dockets@idahopower. com
DEAN J MILLER
McDEVITT & MILLER LLP
420 W BANNOCK ST
BOISE ID 83702
E-MAIL: [e-mail]
KEN MILLER
SNAKE RIVER ALLIANCE
PO BOX 1731
BOISE ID 83701
E-MAIL: [e-mail]
BENJAMIN G HUANG MGR
c/o MOIINTAIN AIR PROJECT
6000 N FOXTAIL WAY
GLENNS FERRY ID 86623
E-MAIL: [e-mail]
PAUL ACKERMAN
ASST GENERAL COUNSEL
EXELON BUSINESS SER CORP
lOO CONSTELLATION WAY
BALTIMORE MD 21202
MICHAEL J YOUNGBLOOD
GREG SAID
IDAHO POWER COMPANY
PO BOX 70
BOrSE rD 83707-0070
E-MAIL: [e-mail]
[e-mail]
RICK KOEBBE PRESIDENT
IDAHO WINDS LLC
5420 W WICHER RD
GLENNS FERRY ID 83623
E-MAIL: [e-mail]
PETER J RICHARDSON
RICHARDSON ADAMS PLLC
515 N 27TH STREET
BOISE ID 83702
E-MAIL: [e-mail]
GREGORY M ADAMS
RICHARDSON ADAMS PLLC
515 N 27TH STREET
BOISE ID 83702
E-MAIL: [e-mail]
TERESA A HILL
K&L GATES LLP
ONE SW COLUMBIA ST
STE 19OO
PORTLAND OR 97258
E-MAIL: [e-mail]
CERTIFICATE OF SERVICE
DINA M DUBSON
RENEWABLE NW PROJECT
421 sw 6rH AVE srE 1125
PORTLAND OR 97204
E-MAIL: [e-mail]
DEBORAH E NELSON
PRESTON N CARTER
GIVENS PURSLEY LLP
PO BOX2720
BOISE tD 8370t-2720
E-MAIL: [e-mail]
prestoncarter@ givenspursley. com
CERTIFICATE OF SERVICE