20061030Sikes Affidavit.pdf

BARTON KLINE , ISB # 1526
LISA D. NORDSTROM , ISB # 5733
Idaho Power Company
1221 West Idaho Street
P. O. Box 70
Boise, Idaho 83707
Telephone: [phone]
FAX Telephone: [phone]
RECEIVED
2006 OCT 27 PM 4: 47
IDtf-irJ fo," if'
UTiLli'iES co1,X(AI SSIOi~
Attorney for Idaho Power Company
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
CASSIA GULCH WIND PARK LLC AND
CASSIA WIND FARM LLC
Respondent
Case No.: IPC-06-
Complainants
Affidavit of DAVID KIP" SIKES
IDAHO POWER COMPANY
STATE OF IDAHO
ss:
County of Ada
David "Kip" Sikes, being first duly sworn upon an oath , deposes and says:
I am Delivery Planning Manager for Idaho Power Company and I hereby make
this Affidavit in support of Idaho Power s Answer and Comments in response to the
Complaint of Cassia Gulch Wind Park, LLC and Cassia Wind Farm , LLC (collectively
Cassia
) .
Description of the Transmission Interconnection Queue Process
Since early 2001 Idaho Power has received over 175 requests for generation
interconnection to the Idaho Power electrical system. Some of these projects have been
merchant requests to integrate projects to transmit power to markets, some for self-
AFFIDAVIT OF DAVID "KIP" SIKES -
generation or net metering, and a number of them have been Qualifying Facilities
(QFs) indicating intent to sell their entire output to Idaho Power. These requests have
come in all sizes, from 3 kW roof-top solar for net metering to plants over 1 500 MW.
The locations of these requests have been just as diverse. The map attached as
Exhibit A to my Affidavit shows the general locations and cumulative MW capacity of
these interconnection requests. While not all projects are ultimately constructed , the
interconnection process administered by Idaho Power must assume each request is
real and will proceed to construction and operation. The Interconnection Queue is
dynamic , in that customers opt to proceed or withdraw their request as milestones are
reached in the process.
Idaho Power s Delivery Business Unit function is responsible for interconnection
of all generators to the Company s electrical system. This is completely independent of
any power purchase or sales agreements between the developers and subscribers of
such projects. The primary intent of Idaho Power s Delivery Business Unit is to safely
and reliably interconnect and integrate the generation projects at the lowest possible
cost while using our best efforts to meet the Applicants' schedules.
As part of this customer-driven process , Idaho Power conducts technical studies
in three phases:
1. Feasibility Study - determines through limited system modeling and analysis if
there are conditions which prevent the full output of the project from being
injected into the system under requirements comparable to a Network Resource.
AFFIDAVIT OF DAVID "KIP" SIKES - 2
2. System Impact Study - further identifies and examines limitations and necessary
construction to mitigate the system deficiencies preventing the project output
from being fully utilized as a Network Resource.
3. Facility Study - engineering design of the system construction and improvements
consisting of Interconnection Facilities , Special Facilities, and Network Upgrades.
Under Idaho Power s Commission approved Schedule 72 INTERCONNECTIONS
TO NON-UTILITY GENERATION and the Federal Energy Regulatory Commission
FE RC") generation interconnection processes , the construction and modification of
facilities identified as part of these studies are the result of non-discriminatory technical
analysis to ensure safe and reliable system operation. As part of that analysis , Idaho
Power is required to review not only the specific equipment at the point of
interconnection , but also to review the cumulative impact on the adjacent area and other
customers.
II.Cassia Contributes to the Need for System Upgrades
Cassia Gulch Wind Park LLC and Cassia Wind Farm LLC , are among the
generation projects within the area of system impact. While the incremental impact of
either of these projects may appear diminutive , multiple projects injecting power into the
same part of the electrical system have a significant cumulative impact.
Earlier this year Idaho Power reviewed the known system limitations and created
a system impact report entitled "Generator Interconnection System Impact Study Report
for Up to 305 MW of New Generation On the 138 kV Transmission System In the Twin
Falls Area." This report is dated June 8 , 2006 and was prepared in response to multiple
AFFIDAVIT OF DAVID "KIP" SIKES - 3
requests in the area to identify the backbone transmission system improvements
required to provide Network Resource Interconnection Service.
The Network System Impact Study results identified four phases of transmission
improvements required to accommodate various levels of new Network Resource
Interconnection Service in the Twin Falls area.The report was performed on a
comparable basis without regard to project intent or determination of QF or FERC
jurisdictional status. It is important to note, as required in evaluation of Network
Resources, these study results and identified transmission system improvements are
indifferent to project type, disposition of energy, or other contractual issues.
These four phases of transmission improvements and the report were discussed
with Commission Staff, Cassia and other developers in the queue at a meeting held at
Idaho Power on August 15, 2006. Specifically, Idaho Power s Delivery Business United
detailed the capacity added to the system by each phase of construction requirements
and the associated costs. These improvements are required to ensure the safe
operation of the system and comply with the reliability criteria of Idaho Power , the
Western Electricity Coordinating Council (WECC) and the North American Electric
Reliability Council (NERC) reliability criteria -- irrespective of which projects consume
the transmission capacity, or in what order they are interconnected to the system.
III.Cassia s Claim That Idaho Power Engineering and Planning
Assumptions are too Conservative is Incorrect.
In the transmission network, the designation of a Network Resource indicates the
ability of the specified project to inject the full plant output into the electrical system and
meet all reliability and operating criteria. As part of the technical studies, one of the
AFFIDAVIT OF DAVID "KIP" SIKES - 4
reliability criteria tests evaluates the loss of a single element (N minus 1 contingency, or
1). In this study, the required capacity improvements were based upon the
occurrence of a remaining system element becoming overloaded for one or more single
contingencies.
In their Memorandum , Cassia asserts that Idaho Power is overly conservative in
determining the acceptable overload prior to requiring Network Upgrades. Idaho
Power s Reliability Criteria for System Planning states:
Short-term emergency ratings are typically 110% of
nameplate during the summer and 120% of nameplate
during the winter. The short-term ratings infer that
equipment loading can be reduced to the normal thermal
rating within an hour. For near term planning, actual
equipment ratings may be determined by performing detailed
studies on the equipment and the involved system.
The System Impact Study Report conforms to these criteria. Specifically the report
states that the Midpoint Series Capacitor Banks are capable of 110% overload on a
continuous basis , which is consistent with the statement regarding actual equipment
ratings for specific equipment.
In Footnote 2 of its Complaint and Memorandum , Cassia takes issue with Idaho
Power s use of a 100% loading limit applied to a transmission line instead of 110% as
suggested by a short-term emergency rating. However, in this instance the generation
additions creating the emergency overload are non-dispatchable thereby preventing
Idaho Power from reducing the overload to normal thermal rating within an hour.
Therefore Idaho Power used the normal thermal rating as the limiting condition. This
decision was not unduly conservative in light of the resources to be connected and was
AFFIDAVIT OF DAVID "KIP" SIKES - 5
required to ensure safe and reliable operation of the system and compliance with
reliability criteria.
Cassia also claims the use of Special Protection Schemes or Remedial Action
Schemes should be allowed in lieu of construction of transmission upgrades. Further
Cassia implies that Idaho Power Delivery is operating in a discriminatory fashion in that
the transmission upgrades would not be constructed if Idaho Power were the entity
developing the wind generation in the Twin Falls area. This is simply not the case.
Remedial actions are automatic control systems initiated following a transmission
disturbance. The utilization of remedial action schemes (RAS) or special protection
systems is allowed to prevent system breakup or voltage collapse. RAS is not utilized
to mitigate minor transmission line or equipment overloads as described by Cassia.
Almost exclusively, RAS is deployed to prevent system instability and cascading
outages. The WECC's Remedial Action Scheme Design Guide referred to by Cassia is
merely a design guide - the WECC Operating Procedures delineate the remedial action
schemes contained within the WECC and demonstrate common and accepted utility
practice with such schemes. The majority of actual systems in service in the WECC
address significantly more serious conditions than line overloads. Although it is not a
long-term solution , Idaho Power is willing to deploy RAS at the generator s expense as
a bridge or temporary solution while the transmission upgrades are being constructed
as required to fully integrate the generation project(s). This accommodation would allow
the generator to begin operation and meet their desired in-service date , should the
remaining system improvements require additional construction time due to long-lead
equipment or siting and permitting delays.
AFFIDAVIT OF DAVID "KIP" SIKES - 6
Due to the nature of the electrical network, all facilities required to interconnect
generation project(s) and meet the safety and reliability criteria become an integral part
of the system. While Interconnection Facilities are typically referred to as those required
to "hook up" the generator to the system, once the electrical output becomes co-mingled
and flowing on multi-use facilities, the Network Upgrades or transmission system
improvements identified in the interconnection study processes are an essential
requirement as part of the project interconnection for reliable operation of the system.
Interconnection facilities, special facilities and network upgrades are collectively
required to be comparable to Network Resource integration to ensure that all electric
output can flow through the system at any given time.
IV. Idaho Power Would Not Construct the System Improvements in the
Twin Falls Area Except for the Requirement to Integrate the Proposed Generation
Projects
These required transmission improvements are the direct result of integration of
the proposed generation , and would not be required otherwise. Idaho Power has
numerous places on its system where significant investment in transmission facilities
will be needed to serve a growing customer base, and would choose to fund those
improvements instead if given the choice. It is true that additional resources and
transmission improvements will be required on Idaho Power s system. However, Idaho
Power plans and constructs this infrastructure according to actual need. If the resources
were interconnected to the electrical system at different location , the total
interconnection and integration costs would likely be different - in some locations the
costs would be higher and in other locations there may not be any transmission costs.
AFFIDAVIT OF DAVID "KIP" SIKES - 7
The total costs, including required transmission improvements , provide the appropriate
price signal for efficient and economical siting of new resources.
For this reason alone, it is important to consider the total costs of locating
projects and to recognize cost responsibility created by those choices. Given the
number and size of projects seeking interconnection in the Twin Falls area, Idaho
Power proposed a cost-sharing mechanism which equitably spread costs of the
required transmission improvements based upon queue position and project capacity.
Idaho Power s Investment in Borah-West is Consistent
with its 20041RP
The lead time required to construct transmission projects is significant. Complex
transmission projects such as the Borah West upgrade can easily require seven years
or more to complete. Construction lead times necessitated proceeding with the Borah
West upgrade project prior to selection of the specific resource projects identified in
Idaho Power s 2004 IRP. As noted in Mr. Schellberg s comments cited in Cassia
Memorandum , the Borah West project should be implemented in 2007, which is later
than initially requested. These types of time delays further support the decision to
proceed at that time.
Idaho Power s 2004 Integrated Resource Plan called for completion of the Borah
West transmission upgrade in 2006. Specifically on page 80 of the 2004 IRP, the
resource acquisition process included the request of Idaho Power Delivery to increase
transmission capacity on the Borah West path to integrate resource additions identified
in the 2004 IRP or to allow additional imports from the east side.
AFFIDAVIT OF DAVID "KIP" SIKES - 8
The action plan in the 2004 IRP identified resource additions to be acquired through a
formal Request For Proposal (RFP) process. This RFP process differs from QFs , in that
bids are solicited and evaluated according to specific criteria , including total costs.
Costs of required transmission upgrades are included as part of the bid evaluation
process in resource selection, as was contemplated in the 2004 IRP determining the
preferred resource portfolio. Thus the costs of transmission upgrades are assigned
directly to the generation projects through the RFP process , contrary to Cassia
inference otherwise.
FURTHER YOUR AFFIANT SA YETH NAUGHT.
~~_
alld Kip" Si
SUBSCRIBED and SWORN to before me this Z7K day of October, 2006.
, 'II""'"
, ~f". /fo
..:::.
'9 ........
'(., " .. .
i8.
:--. .
.:..o..
, . : ..= -
! ~OT A~ (I) \
: . : -.-
\ \ PUBL\
1/1 .
. .~ ~. .
. AO ~
-1,. ....... to-'~ ,Ii OF \~ ,,
..""....""
OTARY PUBLIC FOR IDAHO
Residing in Boise , Idaho
My Commission Expires: 6 - -~Oc:J
AFFIDAVIT OF DAVID "KIP" SIKES - 9
CERTIFICATE OF MAILING
I HEREBY CERTIFY that on the 7fh.day of October 2006 , I served a
true and correct copy of the within and foregoing document upon the following named
parties by the method indicated below, and addressed to the following:
Scott Woodbury
Idaho Public Utilities Commission
472 W. Washington Street
O. Box 83720
Boise, Idaho 83702
Hand Delivered
S. Mail
Overnight Mail
FAX
Email: scott.woodburv(fYpuc.idaho.qov
Dean J. Miller
McDevitt & Miller, LLP
420 W. Bannock
Boise, Idaho 83702
Hand Delivered
S. Mail
Overnight Mail
FAX
Email: dean (fY mcdevitt-miller.com
Ronald K. Arrington
Associate Chief Counsel
John Deere Credit
6400 NW 86th Street
Johnson, IA 50131
Hand Delivered
S. Mail
Overnight Mail
FAX
Email: arrinqtonronaldk(fY johndeere.com
Peter J. Richardson
Richardson & O'Leary
515 N. 2ih Street
O. Box 7218
Boise, Idaho 83702
Hand Delivered
x U.S. Mail
Overnight Mail
FAX
Email: peter(fY richardsonandolearv.com
Lawrence R. Lieb Hand Delivered
Exergy Development Group of Idaho, LLC x U.S. Mail
910 W. Main Street, Suite 310 Overnight Mail
Boise , Idaho 83702 FAX
Email: Irllal(fYsbcqlobal.net
David J. Meyer
Vice President, Chief Counsel for
Regulatory and Government Affairs
A vista Corporation
O. Box 3727
1411 E. Mission Ave.
Spokane, WA 9220
Hand Delivered
x U.S. Mail
Overnight Mail
FAX
Email: dmever(fY avistacorp.com
AFFIDAVIT OF DAVID "KIP" SIKES - 10
Brian Dickman
Dean Brockbank
Pacificorp
201 S. Main , Suite 2300
Salt Lake City, UT 84111
Hand Delivered
x U.S. Mail
Overnight Mail
FAX
Email: brian.dickman(g)pacificom.com
dean. brockban k
(g)
pacificorp. com
Jeff Schlect
Manager, Transmission Services
Avista Corporation
O. OBx 3727
1411 E. Mission Ave., MSC-
Spokane , VVA 99220
Hand Delivered
x U.S. Mail
Overnight Mail
FAX
Email:
nJ1a-
BARTON L. KLINE
AFFIDAVIT OF DAVID "KIP" SIKES - 11
ID AH POWER CO MP ANY
CASE NO. IPC-O6-
AFFID A VIT OF DAVID SIKES
EXHIB IT A
Ge
o
g
r
a
p
h
i
c

D
i
s
t
r
i
b
u
t
i
o
n

o
f

I
d
a
h
o

P
o
w
e
r

G
e
n
e
r
a
t
i
o
n

I
n
t
e
r
c
o
n
n
n
e
c
t
i
o
n

Re
q
u
e
s
t
s
as

o
f

O
c
t
o
b
e
r

20
0
6
Um
a
t
i
l
l
a
Le
g
e
n
d
cI

Ge
n
e
r
a
t
i
o
n

I
n
t
e
r
c
o
n
n
e
c
t
i
o
n

P
r
o
j
e
c
t
s
Pr
o
j
e
c
t
s

a
s

p
e
r
c
e
n
t

o
f

R
e
q
u
e
s
t
s
MW

a
s

p
e
r
c
e
n
t

o
f

R
e
q
u
e
s
t
s
18
3

T
o
t
a
l

R
e
q
u
e
s
t
s
23
4

M
W

T
o
t
a
l

R
e
q
u
e
s
t
e
d
Gr
a
n
t
Ma
l
h
e
u
r
Ha
r
n
e
y
OW
Y
H
E
E
CI
I
CA
S
S
I
A
Si
k
e
s

A
f
f
i
d
a
v
i
t

-

E
x
h
i
b
i
t

A
I
P
C
-
O6
-