20200925IPC to Staff 1-12.pdf

sEm.
An IDACOnP Company
LISA D. NORDSTROM
l-cad Counsol
lnodstrpmAidahooower.conr
September 25,2020
VIA ELECTRONIC FILIilG
Jan Noriyuki, Secretary
ldaho Public Utilities Commission
11331 W. Chinden Blvd., Bldg.8, Ste.201-A
Boise, ldaho 8372O-OO7 4
Re: Case No. IPC-E-20-30
In the Matter of ldaho Power Company's Application for Authority to
Establish Tariff Schedule 68, lnterconnections to Customer Distributed
Energy Resources
Dear Ms. Noriyuki:
Attached for electronic filing, pursuant to Order No. 34602, is ldaho Power
Company's Responsesto Commission Staffs First Production Request, Nos. 1 through 12.
lf you have any questions about the attached document, please do not hesitate to
contact me.
Very truly yours,
X* !-7(^1.t,.*,
Lisa D. Nordstrom
LDN:slb
Enclosure
LISA D. NORDSTROM (lSB No. 5733)
ldaho Power Company
1221 West ldaho Street (83702)
P.O. Box 70
Boise, ldaho 83707
Telephone: [phone]
Facsimile: [phone]
lnordstrom@idahooower. com
Attorney for ldaho Power Company
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF IDAHO POWER
COMPANY'S APPLICATION FOR
AUTHORIW TO ESTABLISH TARIFF
SCHEDULE 68, INTERCONNECTIONS
TO CUSTOMER DISTRIBUTED
ENERGY RESOURCES.
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CASE NO. IPC-E-20-30
IDAHO POWER COMPANY'S
RESPONSES TO COMMISSION
STAFF'S FIRST PRODUCTION
REQUEST
COMES NOW, ldaho Power Company ("ldaho Poure/' or'Company'), and in
response to the First Production Request of the Commission Staff to ldaho Power
Company dated September 4,2020, herewith submits the following information:
IDAHO POWER COMPANY'S RESPONSES TO COMMISSION STAFF'S FIRST
PRODUCTION REQUEST - 1
REQUEST NO. 1: ln its proposed Schedule 68, the Company defines a
Distributed Energy Resource (DER) as "...a souroe of electric power that is not directly
connected to the bulk power system. Any combination of Generation Facilities and/or
Energy Storage devices connected in Parallel is considered a DER." Ptease define the
term "bulk power system."
RESPONSE TO REQUEST NO. 1: The Western Electricity Coordinating Councit
(WECC") provides the below definition for the bulk power system.
Four major electric system networks serve the United States and Canada. Two
major networks, the Western lnterconnection and Eastem lnterconnection, are
divided roughly where the Rocky Mountrains meet the Great Plains. Quebec and
most of Texas are served by their own interconnections. There are physical
asynchronous oonnections between the Western, Eastern, and Texas
lnterconnections, but little if any electricity is exchanged between them. The
generating resources and high-voltage transmission equipment that make up
these networks constitute the bulk power system. Together these components
generate and deliver electricity to customers across North America. The butk
power system does not include localdistribution systems, which generally
operate at lower voltages.
The definition can also be found on the WECC website at:
https://www.wecc.oro/eoubs/StateOffhelnterconnection/Paqesffhe-Bulk-Power-
System.aspx
The response to this Request is sponsored by Jared Ellsworth, Transmission,
Distribution and Resource Planning Director, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSES TO COMMISSION STAFF'S FIRST
PRODUCTION REQUEST - 2
REQUESf NO. 2: On page 5 of proposed Schedule 68 the Company states,
"Disconnection Equipment will be installed at an elec'trical location on the Customer
Generato/s side of the Company's retail metering point to allow complete isolation of
the Custome/s DER and lnterconnection Facilities from the Customer Generato/s other
electrical load and service." ln the same section, the Company provides the following
disclaimer, "The disconnection may result in interruption of both energy deliveries from
the Customer Generator System to the Company as wel! as interruption of energy
deliveries from the Company to the Customer Generator."
Given that the disconnection equipment is located so that it completely isolates
the Custome/s DER/lnterconnection facilities from the Custome/s electrical load and
seryice, please explain why disconnection could result in interruption of energy
deliveries to the customer.
RESPONSE TO REQUEST NO. 2: The specific design and layout of the
Custome/s electrical equipment and building may require disconnecting service from
ldaho Power to operate the generation disconnect switch safely. Systems that are
connected at 480V cannot be safely operated while energized. For these systems,
disconnecting the service would be required in order to open the generator switch.
Also, some customers have elected to connect some of their load directly to the
generator side of the disconnect switch. That load will lose service when the generator
switch is opened. While it is not the intent to disconnect the customer service to
operate the generation switch, in some instances, the specific conditions require this
additional step.
The response to this Request is sponsored by Jared Ellsworth, Transmission,
Distribution and Resource Planning Director, ldaho Power Company,
IDAHO POWER COMPANY'S RESPONSES TO COMMISSION STAFF'S FIRST
PRODUCTION REQUEST - 3
REQUEST NO. 3: ln Table 1 of Schedule 68, the Company proposes default
settings of Vr=0.92ol0, Vz=0.98o/o,Vs=1.03%, and Vl = 1.06%. Please confirm that these
should actually read vr=0.92, vz=0.98, v3=1.03, and v+=1.06 per unit (pu).
RESPONSE TO REQUEST NO. 3: The valuee in Table 1 of Schedute 68 shoutd
be Vr=0.92, Vz=0.98, Vs=1.03, and Vl=1.00 per unit ("pu).
The response to this Request is sponsored by Jared Ellsworth, Transmission,
Distribution and Resource Planning Director, ldaho porrver company.
IDAHO POWER COMPANY'S RESPONSES TO COMMISSION STAFF'S FIRST
PRODUCTION REQUEST .4
REQUEST NO. 4: The values of Vg and Ve in proposed Schedule 68 (Table 1)
differ from the default settings recornmended in Table 8 of IEEE 1547-2A18. Please
explain why the Company proposes these particular values.
RESPONSE TO REQUEST NO.4: ldaho Powe/s standard substation
transfonner load-tap-changer (LTC) and standard distribution regulator set-point is
1.017 per unit (122 volts) with a +/- 1.5-volt deadband. The top end of this range is 1.03
per unit (123.5 volts), which matches the recommended Va setting. ldaho Power's goal
by establishing this voltage setting for the smart inverters is to limit interactions between
the equipment. By raising Vs to the proposed value, the LTC or distribution regulator
operation will occur first while limiting the need for customer equipment to provide
voltage support.
The V+ setting proposed is just beyond the upper limit of ANSI voltage limit B,
which is 1.058pu (127 V). The default vatue for V+ is 129.6V. ldaho Powe/s goal by
establishing this higher voltage setting for smart inverters is to have the smart inverter
provide all reactive support available before voltage exceeds the acceptable steady-
state range.
The response to this Request is sponsored by Jared Ellsworth, Transmission,
Distribution and Resource Planning Director, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSES TO COMMISSION STAFF'S FIRST
PRODUCTION REQUEST .5
REOUEST NO. 5: Please provide the following:
a. The list of smart inverters cunently approved by ldaho Power for use on
its system;
b. The criteria for determining whether a smart inverter can be added to the
!ist; and
c. The process that is used for adding a smart inverter to the approved list.
RESPONSE TO REQUEST NO. 5: Please see responses to parts a - c, below:
a. The Company does not intend to maintain a public list of smart inverters
approved by ldaho Power. lnstead, approved smart inverters would be
those that comply with the latest IEEE-1547 standard and are configured
in accordance with the specifications provided in Schedule 68. The
Company is not opposed to creating and maintaining a public list.
However, it is concerned (1) it may be quickly outdated as inverter
manufacturers release new or cease production of obsolete equipment
and (2) not be wholly inclusive of acceptable inverters.
b. The Company intends to utilize the Underwriters Laboratories 1741
Supplementa! B ("UL 1741SB") certification to identify what inverters
comply with the latest IEEE-1547 standard. However, the UL 1741 SB is
not yet available. ln the interim period, Undenrriters Laboratories 1741
SupplementalA ("UL 1741SA') is widely accepted as an alternative. The
UL 1741SA inverters will meet all but one of the smart inverter settings
outlined in Schedule 68. All seftings will remain the same as listed in
Schedule 68.
c. ln the event the Company has not previously certified that a given inverter
meets the UL 1741 SB or UL 1741 SB certification, the Company will ask
]DAHO POWER COMPANY'S RESPONSES TO COMMISSION STAFF'S FIRST
PRODUCTION REOUEST .6
the installer or the customerto supply the inverter specificatione provided
by the inverter manufacturer.
The response to this Request is sponsored by Jared Ellsworth, Transmission,
Distribution and Resource Planning Director, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSES TO COMMISSION STAFF'S FIRST
PRODUCTION REQUEST -7
REQUEST NO. 6: Please provide any studies conducted by the Company or on
its behalf regarding the ability of the Company's proposed ride-through settings to
prevent cascading in portions of the grid with high DER penetration rates.
RESPONSE TO REQUEST NO.6: The Company has not completed studies
regarding the ability of the proposed ride-through settings to prevent cascading in
portions of the grid wtth high DER penetration rates. However, the Company has relied
on the studies performed by industry peers to establish settings in the latest IEEE 1547
standard. Additionally, the Company has relied on information found in Reliability
Guideline; Bulk Power Sysfem Reliability Perspectives on the Adoption of IEEE 1547-
2018, published in December 2019. These guidelines can be found on the North
American Electric Reliability Corporation ("NERC") website:
httos://www.nerc.com/comm/PC Reliabilitv Guidelines DL/Guideline IEEE 1il7-
2018 BPS Perspectives.pdf
The response to this Request is sponsored by Jared Ellsworth, Transmission,
Distribution and Resource Planning Director, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSES TO COMMISSION STAFF'S FIRST
PRODUCTION REQUEST .8
REOUEST NO:7: Please provide any studies conducted by the Company or on
its behalf regarding the Conservation Voltage Reduction (CVR) value of the Gompany's
Smart lnverter Policy.
RESPONSE TO REOUEST NO. 7: The Company has not conduc{ed the
requested studies.
The response to this Request is sponsored by Jared Ellsworth, Transmission,
Distribution and Resource Planning Director, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSES TO COMMISSION STAFF'S FIRST
PRODUCTION REQUEST .9
REQUEST NO. 8: How does the Company propose to prevent islanding?
RESPONSE TO REQUEST NO.8: The IEEE-1547 standard includes
requirements that were developed to prevent islanding. These requirements are
detailed in IEEE 1547 Section 8.1, Unintentional lslanding. ln orderto meetthe latest
IEEE 1547 stiandard, inverters must include some form of active islanding detection and
will be tested as part of the UL lT4l certification. lnverters that are compliant with the
standard will include this feature.
The most common active islanding detection means used today are based on
positive feedback on frequency error. ln this method, when the inverter detects an error
between its "instiantianeouso frequency measurement and a longer-term averaged
frequency measurement, the inverter adjusts its output current in such a way as to
make that frequency error larger. lf the inverter is able to increase the frequency error,
it applies an ever-larger frequency "push' until some trip limit (a frequency trip limit,
phase-locked loop angle or error limit, Rate of Change of Frequency, or some similar
frequenry-related signal) is reached.
The response to this Request is sponsored by Jared Ellsworth, Transmission,
Distribution and Resource Planning Director, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSES TO COMMISSION STAFF'S FIRST
PRODUCTION REQUEST .10
REQUEST NO. 9: Does the Company propose that the voltage-reactive power
settings on page 7 of Schedule 68 apply to non-exporting systems? lf so, please
explain why.
RESPONSE TO REQUEST NO. 9: Yes. The smart inverter seftings would
apply to all systems connected in parallel with the Company's system. Without a
voltage-reactive power setting, a non-export system could stil! cause voltage issues at
the customer's site, or to adjacent customers, that would have to be addressed through
system upgrades absent the smart inverter capability. As an example, a solar
distributed energy resouroe facility can go from zero output to max output almost
instantly with changes in cloud cover. The impact of rapid variations in generation, for
both exporting and non-exporting systems, can be compensated by the smart inverter
voltage-reactive settings to reduce/eliminate noticeable voltage flicker to the customer
and adjacent customers more cost-effectively than system upgrades.
The response to this Request is sponsored by Jared Ellsworth, Transmission,
Distribution and Resource Planning Director, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSES TO COMMISSION STAFF'S FIRST
PRODUCTION REQUEST .11
REQUEST NO. 10: Wl! the inverter settings described on page 7 of Schedule
68 reduce the active power delivered by a custome/s generatorto the customer when
l11o/o of the energy it produces is used by the customer, and none is being exported to
the grid?
RESPONSE LO REQUEST NO. {0: The inverter settings being proposed do not
require the reduction of active pou,Br; instead, the settings require the production of
reactive power.
The response to this Request is sponsored by Jarcd Ellsworth, Transmission,
Distribution and Resource Planning Dircctor, ldaho Power Company.
TDAHO POWER COMPANY'S RESPONSES TO COMMISSION STAFF'S FIRST
PRODUCTION REQUEST - 12
NO. {t : Wllthe inverter settings described on page 7 of Schedule
68 reduce the active power delivered by a custome/s generator to the customer when
some of the energy lt produces is being exported to the grid?
RESFONSE TO REQUEST NO. 11: The inverter settings being proposed do not
require the reduction of active power; instead, the settings require the production of
reactive power.
The response to this Request is sponsored by Jared Ellsworth, Transmission,
Distribution and Resource Planning Director, ldaho power Gompany.
IDAHO POWER COMPANY'S RESPONSES TO COMMISSION STAFF'S FIRST
PRODUCTION REQUEST - 13
REQUEST NO. {2: On page 8 of its Application, the Company states that it will
notify interested parties of the request regarding smart inverters and send a
communication directly to installers known to be operating in its service areas.
a. Please provide copies of the notifications and communications that either
have been, or will be sent to interested parties, stakeholders, and
installers.
b. Please explain how the company identified interested parties,
stakeholders, and installers.
c. Please provide the dates on which notifications and communications were
sent or will be sent.
RESPONSE TO REQUEST NO. 12: Page 8 of the Application states, "ln order
to notify interested parties and stakeholders of the request regarding smart inverters,
the Company will send a communication direcUy to installers known to be operating
in its service area. Subsequent to submifting this fiting, the Company will also update
its customer generation webpage to include a summary of ldaho Power'e request
in this case and will maintain a list of frequently asked questions to address common
customer or installer questions. ln addition to providing advance notice of lts lntent
to file this case, ldaho Power also served its Apptication and tastimony on the
parties of rocord in Case Nos. IPC-E-18-15 and lpc-E-19-15." (emphasis added)
Please see responses to parts a - c listed below:
a. Please see Attachment No. l lor a copy of the email communication sent
to customer generation installers. The company has also posted
Frequently Asked Questions to its website that describes the filing
(hft ps :/funnnnt. id ahopower. com/energy-environ menUg reen-choices/solar-
IDAHO POWER COMPANY'S RESPONSES TO COMMISSION STAFF'S FIRST
PRODUCTION REQUEST .14
power-options-customer{eneration/frequently-asked-questions/). I n
addition to providing advance notice of its intent to file this case, ldaho
Power served its Application and testimony on the parties of rccord in
Case Nos. IPGE-18-15 and IPC-E-19-15.
b. The Gompany's customer generation installer list was developed based on
all installers that submitted customer generation applications to ldaho
Poryer in 2019 and2020 using the contiact information provided on the
application forms. The customer generation installer list included
approximately 240 separate email addresses.
c. The email communication in Attrachment No. 1 was sent on July 24,2024.
The response to this Request is sponsored by Connie Aschenbrenner, Rate
Design Senior Manager, ldaho Power Company.
Respectfully submitted this 25th day of September,2020.
x;
LISA D. NORDSTROM
Attorney for ldaho Power Company
IDAHO POWER COMPANY'S RESPONSES TO COMMISSION STAFF'S FIRST
PRODUCTION REOUEST . 15
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 25s day of September 2020,1 served a true and
correct copy of IDAHO POWER COMPANY'S RESPONSES TO STAFF'S FIRST
PRODUCTION REQUEST upon the following named parties by the method indicated
below, and addressed to the following:
Gommission Staff
Edward Jewell
Deputy Attorney General
ldaho Public Utilities Commission
472 West Washington Street (83702)
P.O. Box 83720
Boise, ldaho 83720-007 4
Idaho Conservation League and NW
Energy Goalition
Benjamin J. Otto
ldaho Conservation League
710 North 6h Street
Boise, ldaho 83702
ldaho Sierra Glub
Lisa Young
Mike Heckler
503 W Franklin Street
Boise, ldaho 83702
ldaho Glean Energy Aesociation, lnc.
("lcEA"l
Preston N. Carter
Givens Pursley LLP
601 West Bannock Street
Boise, ldaho 83702
Hand Delivered
_U.S. Mail
Overnight Mail
-Ffu\_FTP SiteX Email [e-mail]
_Hand Delivered
U.S. Mail
_Overnight Mail
_FA)(_FTP SiteX Email [e-mail]
_Hand Delivered
U.S. Mail
_Overnight Mail_FA)(_FTP SiteX Email [e-mail];
michael. p. heckler@omail. com
_Hand Delivered
U.S. Mail
Overnight Mail
_FA)(_FTP SiteX Email [e-mail];
kend [e-mail]
Stephanie L. Buckner
Executive Assistant
IDAHO POWER COMPANY'S RESPONSES TO COMMISSION STAFF'S FIRST
PRODUCTION REQUEST - 16
BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
CASE NO. IPC-E-20-30
IDAHO POWER COMPANY
ATTACHMENT 1 TO REQUEST NO.12TO
IDAHO POWER GOMPANY'S RESPONSES TO
STAFF'S FIRST PRODUCTION REQUEST
From:
Sent:
To:
Subiect:
Hello,
We are writing to keep the installer community informed of a request made by ldaho power to implement a smart
inverter requirement for new customer projects and to develop a neu, non-export option for customers that do not wish
to export excess net energy to the grid. As part of this filing, ldaho Power atso requested the ldaho publtc tftilities
Commisslon (Commission) approve a new interconnectlon tariff schedule, Schedule G8. lf the request is approved, the
interconnection requirements for customer-owned on-site generation would be moled from Schedule 72,
lnterconnections to Non-Utility Generation to its own schedule, Schedule 58, Interconnections to Customer Distributed
Energy Resources.
Thls filing was submitted in compliance with a Commission order from 2018 (issued in Case No. IPC-E-17-13) directing
ldaho Power to submit a filing related to smart inverteB within tr days of the final adoption of the lnstitute of Electrical
and Electronics Engineers ("|EEE") standards 1547 and 1547.1. The final \EEEL54T.tStandard Conformance Test
Procedures for Equipment lnterconnecting Distributed Energy Resources with Electric Power Systems and Arsociated
lnterfaces was published on May 2L,2020. tn that same case, the Commission also directed ldaho powerto study the
feasibility of a non-export option that could be made available to customers who did not want to export excess net
energy to ldaho Powe/s system.
ln its filing submitted on July 20,zozo,ldaho Power also asked the commission to:
Approve tariff language intended to simplifo and clarfi some components inctuded in the existing
interconnection tariff schedule. Changes include removing the three-year inspection requirements and
lengthening time for non-compliant systems to complete the interconnection process.
lmplement a return trip charge if initial oompany inspections cannot be completed after the custorner or
installer has submitted a System Verification Form certifying the system is ready for inspection. Unfortunately,
not all solar PV systems are ready when we anive to complete our inilial inspections and change the meter. This
proposal ask the commlsslon to approre a return trip fee if the company must make addltional site visits
because one of the conditions on the system verification Form has not been met.
More information about these changes is outlined in the Freouently Asked Questlons (FAQsl provided on our website.
we will keep you updated on the !PUCs decbion regarding these requests as well as any future proposed changes.
ldaho Power, along with other stakeholderc, wilt mntinue to evaluate on-site generation and may propose additionat
changes in future filings. ldaho Power supports clean energy and customer choice. We remain committed to providing
all customers with reliable energy at affordable prices.
For more information, please visit our website at www.idahopower.com/customerqeneration or contact our Customer
Generation Team at 208-388-2559. You can also follow this case (lPC-E-20-30) on the IPUC's website.
Sincerely,
LOC. CG
Friday, July 24,202012:50 PM
LOC. CG
Customer Generation Update
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