20141017IPC to Sierra Club 15-20.pdf

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An IDACORP Company
DONOVAN E. WALKER
Lead Gounsel
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October 17,2014
VIA HAND DELIVERY
Jean D. Jewell, Secretary
ldaho Public Utilities Commission
47 2 W est Washington Street
Boise, ldaho 83702
Re: Case No. IPC-E-14-18
Solar !ntegration Rates and Charges - ldaho Power Company's Responses
to the Second Discovery Requests of Sierra Club
Dear Ms. Jewell:
Enclosed for filing in the above matter are an original and three (3) copies of Idaho
Power Company's Responses to the Second Discovery Requests of Sierra Club.
Also enclosed are four (4) disks containing information responsive to the Sierra
Club's discovery requests.
DEW:csb
Enclosures
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Donovan E. Walker
1221 W. ldaho 5t. (83702)
PO. Box 70
Boise, lD 83707
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
IN THE MATTER OF IDAHO POWER
COMPANY'S APPLICATION TO
I MPLEMENT SOLAR INTEGRATION
RATES AND CHARGES.
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BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
CASE NO. IPC-E-14-18
IDAHO POWER COMPANY'S
RESPONSES TO THE SECOND
DISCOVERY REQUESTS OF
SIERRA CLUB
COMES NOW, ldaho Power Company ("ldaho Powe/' or "Company"), and in
response to the Second Discovery Requests of Sierra Club to ldaho Power Company
dated October 1,2014, herewith submits the following information:
IDAHO POWER COMPANY'S RESPONSES TO THE
SECOND DISCOVERY REQUESTS OF SIERRA CLUB - 1
For Requests 15-16, please reference the Direct Testimony of Phil DeVol, as well
as Exhibit I to that Testimony, the ldaho Power Gompany Solar lntegration
Report (Solar Report).
REQUEST NO. 15: Please reference the Direct Testimony of Philip DeVol at
page 11 and Solar Report at page 9.
a. Please provide the hourly (8760) solar production forecast for each solar
location by scenario, and the aggregate for each scenario, used for the production cost
model.
b. Please also provide the hourly (8760) aggregate wind production forecast
and the hourly load data.
c. With regard to the solar production forecast, as noted in the study, "The
results of the forecast are a unique set of values (average production, upper bound, and
lower bound) for every hour in the year." Please include this set for each location and
scenario as well as the aggregate solar production.
d. Please also provide the total wind and solar energy per hour (8760) as a
percentage of load.
RESPONSE TO REQUEST NO. 15:
a. The solar forecasts used in the production cost model were developed
strictly for the aggregate for each scenario and therefore are not available for each
individual solar location. Please see the Excel file provided on the enclosed CD for the
aggregated solar production forecasts for all scenarios.
b. Please refer to the Excel files provided with the Company's Response to
Sierra Club's Request No. 18. These files contain data as written by the production cost
IDAHO POWER COMPANY'S RESPONSES TO THE
SECOND DISCOVERY REQUESTS OF SIERRA CLUB - 2
model. The hourly wind production and load are respectively in columns G and F.
Please note these are actual wind production and load, not forecast levels.
c. Please see the Excelfile provided on the enclosed CD.
d. Please refer to the Excel files provided with the Company's Response to
Sierra Glub's Request No. 18. These files contain data as written by the production cost
model. The hourly wind production is in column G, hourly load is in column F, and
hourly solar is in column H.
The response to this Request is sponsored by Phi! DeVol, Resource Planning
Leader, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSES TO THE
SECOND DISCOVERY REQUESTS OF SIERRA CLUB - 3
REQUEST NO. 16: With regard to the proposed Phase 2 of the Solar Report,
with potential topics listed on page 18 of the Report, please answer the following
questions:
a. Qualitatively, do you expect that solar integration costs will increase or
decrease for the analyses described in the bullet points on pg. 18, addressing each
bullet point individually. Please provide some explanation of your assessment.
b. Given the qualitative judgments in (a), what should the implications be for
solar projects with PURPA contracts negotiated prior to Phase 2?
RESPONSE TO REQUEST NO. 16:
a. It is possible to express a qualitative expectation for some of the topics
listed on page 18 of the Solar Report. However, for the following topics, it is
unreasonable to state the qualitative effect without a high degree of speculation. For
these topics, the qualitative effect can only be determined through analytical study:
. Alternative water-year types
o lntra-hourtrading opportunities
o Distributed solar systems
. Correlation between solar, wind, and load variability and uncertainty
o Energy imbalance markets (please see the Company's response to
Sierra Club's Request No. 17)
. Voltage/frequency regulation
Qualitatively, solar integration costs would be expected to decrease for the
following topics:
o Shortening the hour-ahead forecast lead time from 45 minutes to
30 minutes
. lmproved forecasting methods
IDAHO POWER COMPANY'S RESPONSES TO THE
SECOND DISCOVERY REQUESTS OF SIERRA CLUB - 4
For the following topics, solar integration costs would be expected to increase:
o Clustered build-out scenarios-geographic clustering increases
variability
o Other solar plant technologies (e.9., tracking systems or varied
fixed-panel orientation). Qualitatively, tracking systems are
expected to exhibit greater variability during morning up ramps and
evening down ramps than fixed-panel systems, which have
relatively low production during the morning and evening.
Finally, based on the study results, smaller build-out scenarios are likely to have
decreased integration costs relative to higher build-outs.
b. lt is the Company's view that the qualitative judgments above have no
implications for solar projects with Public Utility Regulatory Policies Act of 1978
(.PURPA") contracts negotiated prior to Phase 2. Negotiations are based on the first-
phase study results.
The response to this Request is sponsored by Phil DeVol, Resource Planning
Leader, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSES TO THE
SECOND DISCOVERY REQUESTS OF SIERRA CLUB - 5
For Requests 17-18, please reference the First Production Request to ldaho
Power from ldaho Conservation League (lCL Request).
REQUEST NO. 17: Please reference ICL Request No. 7, and answer the
additional question:
a. Does the Company agree that participating in an EIM would reduce the
cosf of providing balancing services (independently of whether it would also reduce the
quantity of the capacity reserve requirement)?
RESPONSE TO REQUEST NO. 17:
a. The cost to develop and operate an "ElM" and ldaho Powe/s allocations
of those costs have not been established. In addition, ldaho Power would incur costs
participating in such a market. Until more is known about an "ElM" design and how its
services are priced, the potential cost savings of an individual service cannot be
determined.
The response to this Request is sponsored by Ronald Schellberg, Engineering
Leader, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSES TO THE
SECOND DISCOVERY REQUESTS OF SIERRA CLUB - 6
REQUEST NO. 18: Please reference ICL Request No. 10 bullets (b) and (c) as
excerpted below and add our request as shown in ifalrbs.
a. Please provide all spreadsheets and other work papers used to derive the
"integration cost per MWh for sola/' figures in Table 8. Please provide hourly (8760)
data if available.
b. Please provide all spreadsheets and other work papers used to derive the
"incremental integration cost per MWh for sola/' figures in Table 9. Please provide
hourly (8760) data if available.
RESPONSE TO REQUEST NO. 18:
a-b. The requested data for parts a and b are included in the Excel files
provided on the enclosed CD. Please note there are two files (base and test) for each
solar penetration level studied. The data in these files are as written by the production
cost model used for the study. Please note hourly production costs are in column CN
and incremental/decremental capacity in reserve amounts for solar are in columns Dl
and DJ. For the test case simulations, the incremental/decremental capacity in reserve
amounts are part of the total incremental/decremental capacity in reserve amounts
(columns DM and DN). For the base case simulations, the incrementa!/decremental
capacity in reserve amounts for solar are not included in columns DM and DN. The
total production cost for each simulation is in cell F1. Please note the total production
cost is the sum of the hourly production costs /ess penalty costs assessed by the model.
Penalty costs are commonly used in optimization modeling to simulate system
constraints; the penalty costs are incuned if the solution allows the given constraint to
IDAHO POWER COMPANY'S RESPONSES TO THE
SECOND DISCOVERY REQUESTS OF SIERRA CLUB.7
be violated. PIease note the penalty costs are not considered real production costs,
and are removed from the tota! production cost.
The response to this Request is sponsored by Phil DeVol, Resource Planning
Leader, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSES TO THE
SECOND DISCOVERY REQUESTS OF SIERRA CLUB - 8
REQUEST NO. 19: What capability will ldaho Power have to accept bids from
PURPA solar plants, or include such capabilities in contract terms, to mitigate system
integration requirements particularly in high integration cost hours, €.9., through ramp
controls? Has ldaho Power evaluated whether such bids will ever result in production
cost savings above the PURPA avoided cost rate, at least for brief periods of time?
RESPONSE TO REQUEST NO. 19: Currently, the ldaho Public Utilities
Commission ("Commission") requires that solar projects with a nameplate rating of 100
kilowatts or larger are negotiated contacts and the starting point for the price
negotiations is the Commission's approved incremental cost lntegrated Resource PIan
('lRP') methodology. A key input into this pricing methodology is the solar projects
specific hourly energy shape. Thus, if a solar project is able to add storage or other
"firming" capabilities to its project, this will increase the overall energy production as we!!
as the project's energy deliveries during peak load hours, which will potentially result in
higher energy prices from the pricing methodology as well as higher overall payments to
the project due to increased kilowatt-hour production. This incrementa! cost IRP
methodology and the resulting prices are independent of the solar integration costs.
Such proposals as referenced in this question have not been proposed nor evaluated.
The response to this Request is sponsored by Randy C. Allphin, Energy
Contracts Coordinator Leader, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSES TO THE
SECOND DISCOVERY REQUESTS OF SIERRA CLUB - 9
REQUEST NO. 20: Please submit any data on forecast solar curtailment from
the production cost runs for each solar scenario, by hour.
RESPONSE TO REQUEST NO. 20: Curtailment of solar was not modeled for
the study.
The response to this Request is sponsored by Phil DeVol, Resource Planning
Leader, ldaho Power Company.
DATED at Boise, ldaho, this 17h dayof October2O14.
IDAHO POWER COMPANY'S RESPONSES TO THE
SECOND DISCOVERY REQUESTS OF SIERRA CLUB. 1O
DONOVAN E. WALKER
Attomey for ldaho Power Company
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 17th day of October 2014 I served a true and
correct copy of IDAHO POWER COMPANY'S RESPONSES TO THE SECOND
DISCOVERY REQUESTS OF SIERRA CLUB 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
472 West Washington (83702)
P.O. Box 83720
Boise, Idaho 83720-007 4
ldaho Conservation League
Benjamin J. Otto
ldaho 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, Idaho 83701
Ken Miller
Snake River Alliance
P.O. Box 1731
Boise, ldaho 83701
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heather@mcdevitt-mil ler. com
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Sierra CIub X Hand Delivered (CD only)
Dean J. Miller U.S. Mai!
McDEVITT & MILLER LLP
420 West Bannock Street (83702)
P.O. Box 2564
Boise, ldaho 83701
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IDAHO POWER COMPANY'S RESPONSES TO THE
SECOND DISCOVERY REQUESTS OF SIERRA CLUB - 11
Matt Vespa
Siena Club
85 Second Street, Second Floor
San Francisco, California 94105
IDAHO POWER COMPANY'S RESPONSES TO THE
SECOND DISCOVERY REQUESTS OF SIERRA CLUB - 12
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