20140917ICL 1-10 to IPC.pdf

Benjamin J. Otto (ISB No. 8292)
710 N 6s Street
Boise,ID 83701
Ph: [phone]x12
Fax [phone]
botto@idahoconservation. org
Attorney for the Idaho Conservation League
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BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
rN THE MATTER OF rDAHO POWER )CASE NO. IPC-E-I4-I8
COMPANY'S APPLICATION TO )
IMPLEMENT SOALR INTEGRATION ) IDAHO CONSERVATION LEAGUE
RATES AND CHARGES.) FIRST PRODUCTION REQUEST
) TO rDAHO POWER
The Idaho Conservation League (ICL) requests the following information from Idaho
Power. Please provide any documents, workpapers, calculations, or information sources that
support any answer. As required by IDAPA 31.01.01.228.02, please indicate the witness who can
answer questions regarding the response and who will sponsor the response at any potential
hearing. If any responses include Excel spreadsheets or other electronic files, please provide them
with all formulas intact and activated. This production request is ongoing. Accordingly, we ask
Idaho Power to provide additional documents and information that may supplement any initial
responses.
Request No l: Please reference the Direct Testimony of Philip DeVol at page 3, lines Ll-23.
a. Do you agree that there is a need to carry extra capacity in reserve to allow bidirectional
response from dispatchable generators to unplanned variations in load? Please explain
why or why not.
b. Electrically speaking, does the scheduling error of load net with the scheduling error of
solar, wind, and other generation? For example, if in the same moment, the load schedule
was off by +5 MW, the solar schedule was offby -3 MW, and the wind schedule was offby
-2 MW, how much balancing reserve capability would be deployed in that instant?
Request No 2: Please reference the Direct Testimony of Philip DeVol at page 6,lines 12-25.
[PC-E-14-18 I
ICL First Production Request to Idaho Power
September 17,2014
Please provide both documents in the referenced testimony: Principles for Technical
Review (TRC) Involvement in Studies of Variable Generation Integration into Electrical Power
Systems and The Evolution of Wind Power Integration Studies: Past, Present, and Future.
Request No 3: Please reference the Direct Testimony of Philip DeVol at page 8-9, lines 11-7.
Please provide both the raw solar insolation data and the transformed solar data for all six
locations that was used in the Company's Solar Integration Study.
Request No 4: Please reference the Direct Testimony of Philip DeVol at page l0,lines 1-22.
Please describe the process(es), if any, used to scale up the solar data from the original
penetration levels to the revised higher penetration levels. Did the Company go back to the
wavelet application and adjust the size of the estimated projects or was another scaling
methodology used?
Request No 5: Please reference the Direct Testimony of Philip DeVol at page 14-15,lines22-12.
Please provide copies of NV Energy's 2011 solar integration study, Arizona Public
Service's 2012 solar integration study, and Tucson Electric Power's 2014 solar integration study,
as well as copies of any other studies relied upon in support of the conclusion that "Idaho
Power's Study results fall within the range reported by other utilities for the cost of integrating
solar generation."
For Requests No.6 through No. 10 please reference Exhibit I to the Direct Testimony of Phil
Devol,Idaho Power Company Solar Integration Report (Solar Report).
Request No 6: Please reference pages 10-11 of the Solar Report (pages 12-13 of Exhibit 1):
a. When calculating the incremental reserve requirement for integrating solar generation,
does the Company net the decremental, incremental, and total capacity needs identified
for solar generation with the decremental, incremental, and total capacity held by the
Company for managing the variability of other generation and load? Please explain why
or why not.
IPC-E-14-18
ICL First Production Request to Idaho Power
September 17,2014
Does the Company acknowledge that the scheduling error associated with solar
generation nets with the scheduling error associated with other resources and load to
form a total system error signal that is statistically smaller than the sum of the errors of
the individual parts? If the Company disagrees with this principle, please explain why.
How much decremental and incremental capacity (in MW) does the Companyhold in
reserve to respond to wind scheduling errors?
d. Has the Company conducted an analysis of the effect of netting the scheduling errors of
solar, wind, other generation, and load on the total reserve requirement? If so, please
provide the results of such analysis. If not, please explain why the Company has not
performed such an analysis.
Request No 7: With respect to pages ll-12 of the Solar Report (pages 13-14 of Exhibit 1):
a. Has the Company conducted a study of the capacity reserve reductions for solar, wind,
other generation, and load that is associated with participating in an energy imbalance
market ('EIM")?
Please explain whether it is physically feasible, from a transmission perspective, for the
Company to participate in:
The CAISO-PacifiCorp EIM expected to go live on October 1,2014.
A Northwest-focused EIM, such as the one being discussed in the Northwest Power Pool.
If it is not feasible, from a transmission perspective, for the Company to participate in
such an EIM, please explain why not.
d. Does the Company agree that participating in an EIM would reduce the capacity reserve
requirement for solar, wind, other generation, and load? If not, please explain why not.
Request No 8: Please reference pages 13-14 of the Solar Report (pages 15-16 of Exhibit 1):
a. Please provide the following constraints and assumptions for all applicable generation
units as they were input into the system operations model:
i. Reservoir headwater constraints;
rPC-E-14-18 3
ICL First Production Request to Idaho Power
b.
c.
b.
1.
ii.
September 17,2014
ii. Minimum reservoir outflow constraints;
iii. Reservoir outflow ramping rate constraints;
iv. Generator minimum/maximum output levels; and
v. Generator ramping rates.
b. Please provide the constraints and assumptions for market purchases and sales as they
were input into the system operations model.
Request No 9: Please reference page 14 of the Solar Report (page 16 of Exhibit 1):
a. The Company states: "To manage variability and uncertainty in load, capacity reserve
equal to 3 percent of load is held on dispatchable generators in the modeling for the solar
integration study." What is the "load" referred to in this statement? Three percent of
peak load? Three percent ofthe day-ahead forecast average load? Three percent ofthe
hour-ahead forecast load? Other?
b. What amount of balancing capacity (in MW) did the Company use in its system
operation model runs?
c. Please provide the Company's 5-minute load data and the associated hourly load schedule
(schedule, load forecast, load base point, or equivalent metric) for all hours in water year
2012.
Request No 10: Please reference page 15 of the Solar Report (page 17 of Exhibit 1):
a. Please provide the production cost estimates for the "base' and "test" cases in their raw
form as produced by the production cost model.
b. Please provide all spreadsheets and other work papers used to derive the "integration cost
per MWh for solar" figures in Table 8.
c. Please provide all spreadsheets and other work papers used to derive the "incremental
integration cost per MWh for solar" figures in Table 9.
IPC-E-14-18
ICL First Production Request to Idaho Power
September 17,2014
CERTIFICATE OF SERVICE
I hereby certify that on this 17th day of September 20I4,I delivered true and correct
copies of the foregoing FIRST PRODUCTION REQUEST TO IDAHO POWER the following
persons via the method of service noted:
Hand delivery:
Jean Iewell
Commission Secretary (Original and 3 copies provided)
Idaho Public Utilities Commission
427W. Washington St.
Boise,ID 83702-5983
Electronic Mail:
Donovan E. Walker
Greg Said
Michael |. Youngblood
Regulatory Dockets
Idaho Power Company
1221 West Idaho Street
P.O. Box 70
Boise, ID 83707
dwalker@idahopower. com
[e-mail]
[e-mail]
[e-mail]
Ken Miller
Snake River Alliance
PO Box 1731
Boise,ID 83701
kmiller@snakeriveralliance. org
Matt Vespa
Sierra Club
85 Second St.,2nd Floor
San Francisco, CA 94105
matt.vespa@sierraclub. org
Dean I. Miller
McDevitt &Miller LLP
420W. Bannock St.
Boise,ID 83702
[e-mail]
IPC-E-r4-18
ICL First Production Request to Idaho Power
Benjamin J. Otto
September 17,2014