20141008IPC to ICL 1-10 .pdf

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An IDACORP Companv
DONOVAN E. WALKER
Lead Gounsel
DEW:csb
Enclosures
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October 8,2014
VIA HAND DELIVERY
Jean D. Jewell, Secretary
ldaho Public Utilities Commission
47 2 W esl Washington Street
Boise, ldaho 83702
Re: Case No. IPC-E-14-18
Solar lntegration Rates and Charges - ldaho Power Company's Response to
the ldaho Conservation League's First Production 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 the ldaho Conservation League's First Production
Request.
Also enclosed are four (4) disks containing information responsive to the ldaho
Conservation League's production requests.
Sincerely,fulL
Donovan E. Walker
1221 W. ldaho St. (83702)
PO. Box 70
Boise, lD 83707
DONOVAN E. WALKER (lSB No. 5921)
ldaho Power Company
1221 West Idaho Street (83702)
P.O. Box 70
Boise, ldaho 83707
Telephone: [phone]
Facsimile: [phone]
[e-mail]
Attorney for ldaho Power Company
IN THE MATTER OF IDAHO POWER
COMPANY'S APPLICATION TO
IMPLEMENT SOLAR INTEGMTION
RATES AND CHARGES.
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BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
CASE NO. rPC-E-14-18
IDAHO POWER COMPANY'S
RESPONSE TO THE IDAHO
CONSERVATION LEAGUE'S
FIRST PRODUCTION REQUEST
COMES NOW, ldaho Power Company ("ldaho Powe/' or "Comp?[y"), and in
response to the ldaho Conservation League's ("!CL") First Production Request to ldaho
Power dated September 17,2014, herewith submits the following information:
IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO
CONSERVATION LEAGUE'S FIRST PRODUCTION REQUEST - 1
REQUEST NO. 1: Please reference the Direct Testimony of Philip DeVo! at
page 3, lines 11-23.
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 off by -3 MW,
and the wind schedule was off by -2 MW, how much balancing reserve capability would
be deployed in that instant?
RESPONSE TO REQUEST NO. 1:
a. Yes. Please see ldaho Powe/s Application, pages 1 and 2:
Due to the variable and intermittent nature of solar
generation, ldaho Power must modify its system
operations to successfully integrate solar power
without impacting system reliability, similar to wind
generation. Idaho Power, or any electrical system
operator, must provide operating reserves from
resources that are capable of increasing or
decreasing dispatchable generation on short notice to
offset changes in non-dispatchable solar generation.
The effect of having to hold operating reserves on
dispatchable resources is that the use of those
resources is restricted and they cannot be
economically dispatched to their fullest capability.
This results in higher power supply costs that are
subsequently passed on to customers.
b. Please see the Company's response to ICL's Request No. 6.
The response to this Request is sponsored by Phil DeVo!, Resource Planning
Leader, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO
CONSERVATION LEAGUE'S FIRST PRODUCTION REQUEST - 2
REQUEST NO. 2: Please reference the Direct Testimony of Philip DeVol at
page 6, lines 12-25.
Please provide both documents in the referenced testimony: Principles for
Technical Review [RC) lnvolvement in Studies of Variable Generation lntegration into
Electrical Power Sysfems and The Evolution of Wind Power lntegration Sfudies; Past,
Present, and Future.
RESPONSE TO REQUEST NO. 2: Please see the PDFs provided on the
enclosed CD.
The response to this Request is sponsored by Phil DeVol, Resource Planning
Leader, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO
CONSERVATION LEAGUE'S FIRST PRODUCTION REQUEST - 3
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 lntegration Study.
RESPONSE TO REQUEST NO. 3: Please see the Excel files provided on the
enclosed CD.
The response to this Request is sponsored by Phil DeVo!, Resource Planning
Leader, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO
CONSERVATION LEAGUE'S FIRST PRODUCTION REQUEST - 4
REQUEST NO. 4: Please reference the Direct Testimony of Philip DeVol at
page 10, lines 1-22.
Please describe the process(es), if any, used to scale up the solar data from the
origina! 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?
RESPONSE TO REQUEST NO. 4: The Company used the wavelet application
to derive the solar production data at al! penetration Ievels studied and did not scale up
from the original penetration levels to the higher penetration levels.
The response to this Request is sponsored by Phil DeVol, Resource Planning
Leader, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO
CONSERVATION LEAGUE'S FIRST PRODUCTION REQUEST - 5
REQUEST NO. 5: Please reference the Direct Testimony of Philip DeVol at
page 1 4-1 5, lines 22-12.
Please provide copies of NV Energy's 2011 solar integration study, Arizona
Public Service's 2012 solar integration study, and Tucson Electric Powe/s 2014 solar
integration study, as well as copies of any other studies relied upon in support of the
conclusion that "ldaho Power's Study results fall within the range reported by other
utilities for the cost of integrating solar generation."
RESPONSE TO REQUEST NO. 5: Please see the PDFs provided on the
enclosed CD.
The response to this Request is sponsored by Phil DeVol, Resource Planning
Leader, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO
CONSERVATION LEAGUE'S FIRST PRODUCTION REQUEST - 6
For Requests No. 6 through No. 10 please reference Exhibit 1 to the Direct
Testimony of Phi! Devol [sic], ldaho Power Company Solar lntegration 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, incrementa!, and total
capacity held by the Company for managing the variability of other generation and Ioad?
Please explain why or why not.
b. 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? lf the Company disagrees with this principle, please explain
why.
c. How much decremental and incremental capacity (in MW) does the
Company hold 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? lf so, please provide the results of such analysis. lf not, please explain
why the Company has not performed such an analysis.
RESPONSE TO REQUEST NO. 6:
a. ldaho Power does not net solar generation schedule errors with other
generation sources, other schedule errors, or load. ldaho Power designed the solar
IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO
CONSERVATION LEAGUE'S FIRST PRODUCTION REOUEST - 7
integration study to identify the integration issues specifically associated with solar
generation. The objective of the solar integration study is to identify the effects of the
intermittent solar generation in order to calculate the integration cost imposed by solar
upon ldaho Powe/s existing system. ldaho Powe/s system design includes the
capability of system dispatchable generators to manage variability in customer load and
other generation. Intermittent solar generation introduces new variability and
uncertainty into system operations.
Because of the inherent differences and levels of confidence in load forecasts
versus forecasts for intermittent generation, such as wind and solar, load forecast errors
are often auto correlated, reflecting a tendency for forecast errors to persist in
magnitude and direction throughout the day, and are more readily addressed as the
system is managed through to real time. However, in order to maintain the reliable
operation and stability of the system, as well as to meet its various regulatory reliability
criteria, the Company must provide adequate reserves based upon the higher
magnitude and nature of the forecast error present in intermittent and variable wind and
solar forecasts. Thus, the challenges in forecasting wind and solar as compared to load
for unit commitment are considerably different, requiring the system to treat differently
the possibility of errors in forecasting these elements of load and resource balance.
b. ldaho Power does not 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. Please see the Company's response to 6.a above.
TDAHO POWER COMPANY'S RESPONSE TO THE IDAHO
CONSERVATION LEAGUE'S FIRST PRODUCTION REQUEST - 8
c. ldaho Power holds a minimum of .25 per megawatt ("MW") for up to 240
MW of wind or 60 MW incremental and 70 MW of decremental reserve for scheduling
errors in real time; however, this is only a minimum and in most cases the operator will
determine what amount of reserve is required beyond the minimum based on system
conditions at that time. Additionally, the Company is required to hold 5 percent
contingency reserve for the amount of wind generation on the system at any given time.
d. ldaho Power has not conducted an analysis of the effect of netting the
scheduling errors of solar, wind, other generation, and load on the total reserve
requirement. Please see the Company's response to 6.a above.
The response to this Request is sponsored by Phil DeVol, Resource Planning
Leader, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO
CONSERVATION LEAGUE'S FIRST PRODUCTION REQUEST - 9
REQUEST NO. 7: With respect to pages 11-12 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 ('ElM')?
b. Please explain whether it is physically feasible, from a transmission
perspective, for the Company to participate in:
i. The CAISO-PacifiCorp EIM expected to go live on October 1,2014.
ii. A Northwest-focused ElM, such as the one being discussed in the
Northwest Power Pool.
c. lf it is not feasible, from a transmission perspective, for the Company to
participate in such an ElM, 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? lf not, please
explain why not.
RESPONSE TO REQUEST NO. 7:
a. Studies conducted by ldaho Power evaluating participation in an energy
imbalance market have not studied capacity reserve reduction as an objective.
b. lt is physically feasible for ldaho Power to participate in a security
constrained economic dispatch.
c. Please see the Company's response to 7.b above.
d. Capacity reserve requirement reductions have not been contemplated to
be a primary objective of participating in a security constrained economic dispatch.
IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO
CONSERVATION LEAGUE'S FIRST PRODUCTION REOUEST - 1O
Capacity reserve reductions might be achievable in the long term once a market has
been operating for many years. The market's operation must be stable and well
understood to achieve any reserve reductions due to larger footprint diversity.
The response to this Request is sponsored by Ronald Schellberg, Engineering
Leader, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO
CONSERVATION LEAGUE'S FIRST PRODUCTION REQUEST - 11
REQUEST NO. 8: Please reference pages 13-14 of the Solar Report (pages 15-
16 of Exhibit 1):
a. PIease provide the following constraints and assumptions for all applicable
generation units as they were input into the system operations mode!:
i. Reservoir headwater constraints;
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.
RESPONSE TO REQUEST NO. 8:
a.i. Reservoir headwater constraints:
Maximum Elevation. Brownlee 2077. Oxbow 1804.5o Hells Canyon 1687.5
ii. Minimum reservoir outflow constraints:
o Brownlee & Oxbow 30 MW combinedo Hells Canyon Oct 1-Oct 14
Oct 1S-June 1
Minimum Elevation
1976
1 800
1683.5
7,000 cfs
13,000 cfs
2,000 cfs
0 cfs
2,000 cfs
Varies based on expected future water year flows.
iii. Reservoir outflow ramping constraints:
o Hells Canyon Oct 1-Oct 14
Oct 15-Dec 6
Dec 7-Sept 30
IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO
CONSERVATION LEAGUE'S FIRST PRODUCTION REQUEST - 12
tv.Generator Minimum/Maximum output levels:
. Bridgero Valmyo Boardman. Upper Snake Hydro. Geo Thermalo Non-Wind CSPPo Bennett MTN GTo Danskin #1. Danskin #2 & 3o Brownlee. Oxbowo Hells Canyon
v. Generator Ramping Rates:
o Bridger. Valmy. Boardmano Upper Snake Hydro. Geo Thermal. Non-Wind CSPPo Bennett MTN GTo Danskin #1o Danskin#2 &3o Brownlee. Oxbowo Hell Canyon
Hour to Hour Limit
None
None
None
Fixed
Fixed
Fixed
None
None
None
None
None
Limited by outflow
Sales
500
500
500
500
500
500
500
500
500
500
500
500
Maximum
707
260
58
500
32
140
163
173
45
730
220
450
Minimum
300
125
0
200
22
42
102
102
34
0
0
0
b.Firm Non-FirmPurchase Purchase
Oct
Nov
Dec
Jan
Feb
Mar
Apr
May
June
July
Aug
Sept
0
113
325
179
35
0
0
320
262
149
230
217
300
300
300
300
300
300
300
300
300
300
300
300
The response to this Request is sponsored by Ronald Schellberg, Engineering
Leader, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO
CONSERVATION LEAGUE'S FIRST PRODUCTION REQUEST - 13
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 of the day-ahead forecast
average load? Three percent of the hour-ahead forecast load? OtheP
b. What amount of balancing capacity (in MW) did the Company use in its
system operation model runs?
c. Please provide the Company's S-minute load data and the associated
hourly load schedule (schedule, Ioad forecast, load base point, or equivalent metric) for
all hours in water year 2012.
RESPONSE TO REQUEST NO.9:
a. The load referred to is ldaho Powe/s average real-time hourly retail load.
b. The regulation capacity held the model run varied by hour:
1. Maximum 97 MW2. Average 53 MW3. Minimum 31 MW
c. Please see the Excel file provided on the enclosed CD. Please note the
five-minute load data are from a PI (Plant lnformation) data query and are not
considered official load data. Hourly load schedule data used in rea!-time operations
are not retained in standard Company practice.
The response to this Request is sponsored by Ronald Schellberg, Engineering
Leader, ldaho Power Company, and Phil DeVol, Resource Planning Leader, ldaho
Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO
CONSERVATION LEAGUE'S FIRST PRODUCTION REQUEST. 14
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 a!! spreadsheets and other work papers used to derive the
"integration cost per MWh for sola/'figures in Table 8.
c. Please provide all spreadsheets and other work papers used to derive the
"incremental integration cost per MWh for sola/'figures in Table g.
RESPONSE TO REQUEST NO. 10:
a-c. PIease see the Excel file provided on the enclosed CD.
The response to this Request is sponsored by Ronald Schellberg, Engineering
Leader, ldaho Power Company, and Phil DeVol, Resource Planning Leader, Idaho
Power Company.
DATED at Boise, tdaho, this 8th day of Octoblr 2014.
IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO
CONSERVATION LEAGUE'S FIRST PRODUCTION REQUEST - 15
Attorney for ldaho Power Company
Commission Staff
Kristine A. Sasser
Deputy Attorney General
ldaho Public Utilities Commission
47 2 W est Washington (83702)
P.O. Box 83720
Boise, ldaho 83720-007 4
ldaho Conservation League
Benjamin J. Otto
Idaho Conservation League
710 North Sixth Street (83702)
P.O. Box 844
Boise, ldaho 83701
Snake River Alliance
Kelsey Jae Nunez
Snake River Alliance
P.O. Box 1731
Boise, ldaho 83701
Ken Miller
Snake River Alliance
P.O. Box 1731
Boise, ldaho 83701
Sierra Club
Dean J. Miller
McDEVITT & MILLER LLP
420 West Bannock Street (83702)
P.O. Box 2564
Boise, ldaho 83701
CERTIFICATE OF SERVIGE
I HEREBY CERTIFY that on the 8th day of October 2014 I served a true and
correct copy of IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO
CONSERVATION LEAGUE'S FIRST PRODUCTION REQUEST upon the following
named parties by the method indicated below, and addressed to the following:
X Hand Delivered (CD only)
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heath e r@mcd evitt- m i I le r. com
IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO
CONSERVATION LEAGUE'S FIRST PRODUCTION REQUEST - 16
Matt Vespa
Siena Club
85 Seoond Street, Second Floor
San Francisco, Califomia 94105
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IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO
CONSERVATION LEAGUE'S FIRST PRODUCTION REQUEST. 17