20201028IPC to Staff 27-28.pdf

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LISA D. NORDSTROilI
Lead Counee!
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October 28,202A
VIA ELECTRONIC FILING
Jan Noriyuki, Secretary
ldaho Public Utilities Commission
11331 W. Chinden Blvd., Bldg.8, Ste.201-A
Boise, ldaho 837204074
Re: Gase No. IPC-E-20-30
ln the Matter of ldaho Power Company's Application forAuthority to Estiablish
Tariff Schedule 68, lnterconnections to Customer Distributed Energy
Resources
Dear Ms. Noriyuki:
Attached for electronic filing, purcuant to Order No. 34602, is ldaho Power
Company's Response to Third Production Request of the Commission Stiaff, Nos. 27
through 28.
lf you have any questions about the attached document, please do not hesitate to
contact me.
Very truly yours,
fr,!.(^t t,-*,
Lisa D. Nordstrom
LDN:slb
Attachment(s)
LISA D. NORDSTROM (lSB No. 5733)
ldaho Power Company
1221 West Idaho 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.
CASE NO. IPC-E-20-30
IDAHO POVVER COMPANY'S
RESPONSE TO THIRD
PRODUCTION REQUEST OF THE
COMMISSION STAFF
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COMES NOW, ldaho Power Company ("ldaho Power' or "Company''), and in
response to the Third Production Request of the Gommission Staff to ldaho Pourer
Company dated October 7,2020, herewith submits the following information:
IDAHO POWER COMPANY'S RESPONSE TO THIRD PRODUCTION
REQUEST OF THE COMMISSION STAFF. 1
REQUEST NO. 27: Please describe the communication protocols needed to
implement smart inverters that can communicate with the Company's SCADA system.
Does the Company cunently perform distribution system modeling using compatible
protocols?
RESPONSE TO REQUEST NO.27: The Company is not proposing the
implementation of communication protocols for Distributed Energy Resources ("DERs")
as part of the smart inverter requirement in this qlse. However, as part of the proposed
interconnection requirements for non-exporting systems 3 MVA or greater,
communication with the DER is required. For inverter-based applications, the Company
anticipates relying upon the Distributed Network Protocol3 ('DNP3'), also known as
IEEE 181s.
lf the Company were to implement communication protocols so that the inverters
lor allDERs could communicate with the Companfs SCADA system, it would likely rely
on the IEEE standards. Specifically, IEEE 1547-2018 includes three (3) communication
protocols that may be used for a DER to communicate with the Area Electric Provider
(,AEP'), IEEE 1815, IEEE 2030.5, and SunSpec Modbus. The Company expects a
residential DER would utilize the IEEE 2030.5 communication protocol, as this protocol
has been built for internet-based communications for large numbers of small devices
and designed with a data modelto represent DER parameters. IEEE 2030.5 is
designed using widely adopted standard web protocoltechnology. The IEEE 2030.5
standard was updated and approved in 2018, similarly to the IEEE 1547 standard
update.
\Mtile the Company uses communication protocols for applications such as
IDAHO PO\'!ER COMPANY'S RESPONSE TO THIRD PRODUCTION
REQUEST OF THE COMMISSION STAFF . 2
energy management systems and system protection systems, the Company does not
cunently use any similar communication protocols in its distribution slatem modeling.
The response to this Request is sponsored by Jared Ellsworth, Transmission,
Distribution and Resource Planning Director, ldaho Pourer Company.
IDAHO POWER COMPANY'S RESPONSE TO THIRD PRODUCTION
REQUEST OF THE COMMISSION STAFF . 3
REQUEST NO. 28: Please describe in detailthe necessary steps the Company
would have to take to communicate with customer smart inverters. Please include
details about any equipment the Company would need to purchase and descriptions of
the work that would need to be performed, with time and cost estimates.
RESPONSE TO REQUEST NO. 28: The Company has not conducted a
thorough review to determine the necessary steps, prooesses, equipment, time, and
c,osts required to implement the communication protocols identified in IEEE 1547 lo
communicate with customer smart inverter controllers. Further, the Company has found
minimal industry experience or best practices to use as a reference. For example, the
California Public Utilities Commission only recently began requiring a communication
protocolfor smart inverters in June 2020. This action was in direct response to the high
level of penetration of DER in that jurisdiction.
\Mtile it has not conducted a complete study to determine all neoessary steps,
the Company anticipates the process would involve purchasing new computer servers
and a software solution to customize a Distributed Energy Resource Management
System ("DERMS') for ldaho Power. The customization would include developing
database structure, system interface screens, data verification algorithms, alarm
seftings, group performanoe parameters, and data refresh rates. To determine a final
scope (including time and cost estimates), the Company would rely on a project team to
map out the various DERMS internal pro@sses, dataflow, setting requirements, and
user training plans. That team would be comprised of functional area subject matter
experts, including but not limited to: the software vendor, internaldatabase
development, inforrnation technology, cybersecurity, SCADA, energy management
IDAHO POWER COMPANY'S RESPONSE TO THIRD PRODUCTION
REQUEST OF THE COMMISSION STAFF . 4
systems, field operations, @mmunications, distribution dispatch, generation dispatch,
distibution planning, transmission planning, GlS, and contrac'ting.
The response to this Request is sponsored by Jared Ellsworth, Transmission,
Distribution and Resource Planning Director, ldaho Power Company.
Respectfully submitted this 28th day of October, 2020.
&L !.7("*+r.-"-,
LISA D. NORDSTROM
Aftomey for ldaho Power Company
IDAHO POWER COMPANY'S RESPONSE TO THIRD PRODUCTION
REQUEST OF THE COMMISSION STAFF - 5
CERT|F|CATE OF SERVTCE (tpC-E-20-30)
I HEREBY CERTIFY that on the 28th day of October 2020,1 served a true and
correct copy of IDAHO POWER COMPANY'S RESPONSE TO THIRD PRODUCTON
REQUEST OF THE COMMISSION STAFF upon the following named parties by the
method indicated below, and addressed to the following:
Commission Staff
Edward Jewel!
Deputy Attorney Genera!
ldaho Public Utilities Commission
472 West Washington Street (83702)
P.O. Box 83720
Boise, ldaho 83720-007 4
ldaho Gonservation loague
Benjamin J. Otto
ldaho Conservation League
710 North 6th Street
Boise, ldaho 83702
ldaho Clean Energy Association
Preston N. Carter
GIVENS PURSLEY LLP
601 West Bannock Street
Boise, ldaho 83702
ldaho Sierra Glub
Lisa Young
Mike Heckler
503 W. Franklin Street
Boise, lD 83702
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michael. p. heckler@g mail.com
IDAHO POWER COMPANY'S RESPONSE TO THIRD PRODUCTION
REQUEST OF THE COMMISSION STAFF.6
ldaho Sierra CIub
Kelsey Jae Nunez
KELSEY JAE NUNEZ LLC
920 North Clover Drive
Boise, ldaho 83703
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Stephanie L. Buckner
Executive Assistant
IDAHO POWER COMPANY'S RESPONSE TO THIRD PRODUCTION
REQUEST OF THE COMMISSION STAFF - 7