20050718Ikemoto direct and exhibit.pdf

Idaho Public Utilities Commission
Office of the SecretaryRECEIVED
JUL 1 5 2005
Boise, Idaho
BEFORE THE IDAHO PUBLIC UTiliTIES COMMISSION
IN THE MATTER OF THE PETITION OF
IDAHO POWER COMPANY FOR AN
ORDER TEMPORARll Y SUSPENDING
IDAHO POWER'S PURP A OBLIGATION
TO ENTER INTO CONTRACTS TO
PURCHASE ENERGY GENERATED BY
WIND-POWERED SMAll POWER
PRODUCTION FACILITIES.
CASE NO. IPC-O5-
ENERGY VISION llC
DIRECT TESTIMONY
GLENN IKEMOTO
Please state your name and business address.
My name is Glenn Ikemato and my address is 672 Blair Avenue, Piedmont, CA.
By whom are you employed?
I am a Principal of Energy Vision LLC.
Describe your educational background.
I have a Bachelors of Science degree in Electrical Engineering from the University of
California at Berkeley and a Masters of Business Administration from Stanford University.
Please describe your work experience.
I joined Kenetech Wind power, Inc. (formerly U.S. Wind power) in 1982, at the
beginning of my second year of graduate school. Prior to graduation , I negotiated a 120
MW non-standard wind contract with Southern California Edison. After graduation, I
represented Kenetech in the negotiation of California s Standard Offer 4. I then progressed
through a series of finance and development positions, ultimately becoming Vice President -
Business Development in 1989. In that position, I was responsible for all sales, marketing,
product development, project acquisition and project development activities of the world'
largest wind energy company.
In 1991 , I became head of Kenetech International, Ltd. with headquarters in Chester
England, UK. As Managing Director, lied the company s entry into Europe and oversaw
development activities in wind, biomass, industrial cogeneration and demand side manage-
ment. We successfully developed green-field wind projects in 4 countries, won a major
competitive bid in the UK and negotiated power contracts and joint ventures with major
international utilities.
After leaving Kenetech in 1995, I continued to work primarily in Europe until the end
of 2004. My partners on the Idaho projects and I have had executive, leading and/or
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financing responsibility for over 600 MW of wind projects in eight countries and raised over
$1 billion in renewable energy financing.
Do you have any other relevant work experience?
Yes, prior to Business School , I worked for four years in the Generation Planning
Department of the Pacific Gas and Electric Company (PG&E). As a Senior Resource
Planner, I directed the unit responsible for the economic analyses of generation alternatives
evaluation of marginal (avoided) cost methodologies and the calculation of avoided costs.
was a member of the California Marginal Cost Pricing Project, negotiated the first long term
renewable energy power purchase agreement in the country and obtained CPUC approval
of that contract, designed the pricing provisions of PG&E's Standard Offers 1 , 2 and 3, built
the generation production simulation module used in the company s Corporate Planning
Model , participated heavily in the Company s load forecasting and resource planning
processes and helped develop the company s PURPA policy (which it supported).
Have you previously testified in hearings such as this?
Yes, I have served as an expert witness for PG&E on issues related to utility
economics, resource planning, power contracts and marginal cost methodologies in
hearings before the CPUC and the California Legislature.
What is the purpose of your testimony?
I oppose the suspension of PURPA contracts on the grounds that it is economically
harmful to customers, bad public policy and bad regulatory procedure. In my testimony, I
will counter all of Idaho Power's unsubstantiated economic and reliability assertions.
Contrary to Idaho Power's position , current Posted Prices are a bargain for customers. With
the luck of timing, the current prices were set before much of the massive run-up in energy
prices. The issues Idaho Power raises are trivial compared to the spread between Posted
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Prices and current market prices. The Commission should encourage signing OF's under
the present prices before they have to be updated.
m sure the Commission s primary concern is determining what is in the public
interest. Idaho Power pointed to the extension of the Production Tax Credit (PTC) and the
recently enacted state sales tax exemption for wind energy as problems. I see these as the
clearest indication of the public interest. Both of these decisions were made by our elected
representatives. They are the people most responsible for determining what is in the public
interest. As recently as April of this year, Idaho s legislature and administration spoke
strongly in favor of developing wind energy in Idaho by enacting the sales tax exemption.
At the federal level , the PTC debate expanded beyond the environmental benefits of
wind energy to include substantial consideration of the need for wind energy to bolster our
national energy security. Absent any economic justification, a suspension of the PURPA
wind contracts would be contrary to both state and federal energy policy.
As for regulatory procedure, I'm sure others will make a better case than me. I would
just like to point out that the Commission is being asked to set aside the results of an
extensive, formal multi-party procedure by a claim of "new" issues. Idaho Power has not
provided studies, analyses or other meaningful evidence to support its claim. The
intermittent nature of wind deliveries was certainly a major consideration in Case IPC-04-
10 and resulted tin the 90/110 Performance Band. The only real new fact is that a meager
27 aMW of wind contracts have been signed. So there was a formal procedure, all parties
had the right to make their case, there was a period for reconsideration and then a final
decision. How is it appropriate for one party to now introduce new information. Idaho
Power is really just appealing a final decision. Isn t the correct avenue for an appeal the
courts? Doing it simply with a new IPUC petition is a terrible precedent.
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In the Commission s Notice of Petition in this case, we were all notified that Idaho
Power s Petition "alone provides insufficient basis to grant the temporary suspension" and
directed Idaho Power to submit additional testimony and exhibits. They responded by
reformatting their petition into testimony and adding no new significant information. This
cavalier approach has led many to question whether the outcome of this proceeding hasn
been pre-determined. This certainly isn t good for the credibility of Idaho s regulatory
process.
My testimony will also address options the Commission may wish to consider to
rationalize the PURPA Contracting process. These suggestions avoid a suspension of
PURPA Contracts.
Should the Commission find that a suspension is in the public interest, we urge you
to limit the damage. First, any moratorium should not to apply it to Avista or Pacificorp. The
other utilities have not yet executed any PURPA Contracts. Idaho Power has raised issues
which focus primarily on the percentage of wind generation on their system (penetration).
Ancillary costs are a function of penetration. In Avista s case, there is very little wind
resource in their Idaho service territory, so there is no penetration issue. In Pacificorp
case, they have a large generating base, so again, penetration is not an issue. Including the
other utilities in a moratorium would be rewarding them for slower implementation. Second,
any new proceeding should not re-litigate closed issues. It should focus solely on the
impact of operating uncertainty, the 90/110 Performance Band and accounting for
uncertainty in avoided costs.
FEAR, UNCERTAINTY AND DOUBT (FUD)
What is your general view of Idaho Power s filings?
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In the days when IBM completely controlled the computer industry, it's competitors
created a term for the marketing strategy of a monopolist. FUD is the fear, uncertainty and
doubt a monopolist attempts to create in the minds of customers (or their representatives)
when they consider new alternatives. It was applied to IBM during the initial years of "IBM
compatible" mainframes and then the era of PCs, as they replaced mainframes. Today it is
often applied to Microsoft. It also describes the strategy of many regulated companies, such
as airlines, as they faced deregulation. Idaho Power s filings are classic examples of FUD.
However, the changes that drove the other industries will also drive the utility industry.
the 1950', economies of scale in power generation propelled today s utility model. With
new technologies in power generation and finance, those economies no longer exist. Just
as IBM's mainframes gave way to distributed computing, utilities will ultimately yield to
distributed generation.
In Mr. Gale s testimony, he states that it became "evident" that the availability
of PURP A prices influenced the RFP process. Do you agree?
, "
evident" is a great FUD word. It implies the existence of evidence, which was
seriously lacking in Idaho Power's filings. They simply point to the Judith Gap project's 32
$/MWh price to demonstrate that wind projects should be far cheaper than prices they
received in the RFP. They provided no side-by-side analysis and possibly didn t even check
on how the contract was structured (which isn t standard). Rather than bid gaming, all we
have here is a simple case of greed and gravity.
Wind developers, right now, are digesting the most severe increases in turbine prices
in the history of the industry. This has been caused by huge increases in the cost of steel
and other raw materials and a lack of turbine supply due to poor federal policies and the
high value of the Euro (increasing the dollar price of European turbines).Manufacturers
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are taking advantage of this to push through previously unimaginable price increases for
2006 deliveries.
Much of the sticker shock from Idaho Power's RFP is caused by bad timing. To my
knowledge, it is the first RFP in the country based on the new turbine prices. The only other
announced project based on 2006 prices is the Los Angeles Department of Water and
Power s 120 MW Pine Tree Wind Farm. According to their May 2005 budget documents
the project was originally planned for $167 million and must absorb a $37 million increase in
wind turbine costs. Since turbines represent approximately 75% of project cost (based on
old prices), this implies an approximately 30% increase in turbine prices since 2004. They
project a power cost of 53 $/MWh (Ievelized) using lower cost public financing.
As for gravity, air, like everything else, is subject to it. It is common knowledge in the
wind industry that you want to locate a project on the downwind side of a hill. On the upwind
side, wind speeds slow down as the air is pushed uphill. On the downwind side, it's a sleigh
ride, as gravity pulls the air downhill. When the hill is the Rocky Mountains, there is going to
be a BIG increase in wind speeds. The difference between the average RFP price and the
Judith Gap price can be entirely explained by the differences in energy production , turbine
prices and property taxes (which are not included in Judith Gap s price), as demonstrated in
Exhibit 1 of my testimony. I should note that some news articles state that the capacity
factor of Judith Gap is 37%. Actually the Montana PSC filings only state that the capacity
factor will be at least 37%. Developers are very protective of their energy estimates. They
often use lower numbers or minimums in public documents. Based on my experience, I
believe the actual capacity factor is expected to be significantly higher.
Does this mean that wind energy in Idaho is not economic?
No, Idaho Power notes that it's 2004 IRP assumption for wind energy was only 43
$/MWh , and implies that a price of 55 $/MWh would change the plan. That's is just another
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FUD technique. If the results don t support your position then pick out an isolated fact that
does and skip the results. They are well aware that planning results are based on relative
costs, not absolute costs. Although the cost of wind energy has increased 28Ok from the
2004 IRP assumption, natural gas prices have increased over 50ok and coal-fired energy
has also certainly increased above it's IRP assumption. To a certain extent, all energy
technologies are driven by the cost of oil because of materials and transportation costs.
if we want to reassess the validity of the IRP results in light of new cost information , we have
to look at all costs, not just the cost of wind energy. At 55 $/MWh , wind still beats natural
gas and it still beats coal. Demand would probably decline a little due to price elasticity, so
a new resource plan would just delay the coal plant. I think that's what we all want , isn t it?
Wind is still the lowest cost resource, whether by RFP or PURPA Contract.
The 2004 price assumption of 43 $/MWh for wind energy would have been
appropriate at the time. This underscores the need to avoid further delay as costs increase.
Otherwise, Idaho Power may file a petition in 2007 saying that in 2006 they planned for wind
energy at only 55 $/MWh, but now it's 70 $/MWh and that's too expensive.
Can you summarize other areas of unsubstantiated assertions by Idaho
Power?
Sure, they hit all the classics. We ve got a FUD tsunami here , so I'll just cover the
highlights. Idaho Power states that the addition of large amounts of wind energy could
aversely affect system reliability. That's always FUD number 1 - the system s going to
crash! It's an easy thing to say if you don t have to define "large I would say at a minimum
they should be comfortable with the amount of wind energy in their IRP. Those plans are
subject to reliability analyses and they can t say they aren t ready for what is already in their
plan. Also , there are states with Renewable Portfolio Standards (RPS) targeting 20% of
energy production. Much of this is expected to come from wind projects since they are
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usually the lowest cost renewable energy option. This implies a far higher percentage of
capacity, well beyond what's being considered in Idaho.
Here s another classic, which is typically FUD number 2: from Page 12 of the
testimony, line 23, "a 10 MW wind facility may be at full output at one moment and minutes
later be at a very low to no output." That could just as easily be the description of any power
plant's forced outage. So what is the logic here? If the wind plant loses output because of
mechanical failure and stays broken (like a thermal outage) then is that supposed to be
better than being able to come right back on line when wind conditions permit? Utilities deal
with power plant forced outages, load variability and transmission failures. Wind energy
won t be any different.
This one is pretty popular: "PURPA Contracts will lock the customers into high
prices How many times have we heard that one? We ve all seen natural gas prices rise
and fall. In the past, that was caused by market manipulation by fossil fuel traders. The
current run up in prices is being driven by far more permanent conditions. Any ancillary
costs associated with wind energy are minor compared to existing fossil fuel increases.
things stand now, the current Posted Prices are a bargain for the customers. They
effectively getting gas at a 50010 discount. Lock-ins (fixed prices) work both ways, so given
the large increases in all energy costs since the Posted Prices were set, it is far more likely
that PURPA Contracts will lock the customers into low prices.
Idaho Power has thrown out a number of 193 MWof potential PURPA wind projects
waiting in the wings. Without any documentation, it is impossible to know whether these
represent real projects with viable transmission options or just wishful thinking. Absent any
meaningful information, this is just a scare tactic.
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ANCILLARY COSTS
Do you agree that wind energy projects create ancillary costs for the utility?
Surprisingly, yes I do. I think there are three important points: the cost is small, the
cost is adequately offset by the 90/110 Performance Band and the avoided cost
methodology ignores all uncertainty.
There have been numerous studies of wind related ancillary costs conducted by
other utilities. These companies were not necessarily friends of wind energy and the wind
energy community has several criticisms of their methodologies. However, at the
penetration level in Idaho Power's IRP , they estimate costs of 2.5 $/MWh or less. We
predict the 90/110 Performance Band has about the same effect. Compare this to natural
gas prices, which are up 14 $/MWh on an SAR basis. Why stop wind energy when, in the
worse case, economics have improved 11.5 $/MWh.
Ancillary costs are created by the scheduling uncertainty associated with the wind
resource. All uncertainty creates costs. If it appropriate to include operating uncertainty in
avoided costs, then it should be equally appropriate to include planning uncertainties. In a
case where all uncertainties are included in avoided costs, Posted Prices would be higher.
Do you agree with Idaho Power that issues related to the intermittent nature of
wind have not previously been considered by either Idaho Power or the Commission?
Absolutely not, as I have mentioned, the intermittent nature of wind was a
fundamental part of Case IPC-04-10. It was the wind developers' objection to the 90/110
Performance Band that was one of the primary issues in the case. This dealt specifically the
operating reliability of wind deliveries. The Commission considered all the evidence that
was presented and decided , over the objections of the wind energy community, to leave in a
form of the 90/110 Performance Band. Idaho Power did not object to this new form or
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anything else in the decision. Now we have a situation where Idaho Power won the point
and they are still using it against wind projects.
INTERACTION OF RFP AND PURPA PROJECTS
If 55 $/MWh is a fair price for wind energy in Idaho, why have PURPA Contracts
at 61 $/MWh?
PURPA Contracts will not receive 61 $/MWh. The 90/110 performance band and
seasonality factors do not apply to RFP contracts. These terms lower the effective price of
PURPA Contracts. We expect average revenues at our project in Idaho Powers territory to
be reduced by 6%, with a 1 % reduction for seasonality and 5O~ reduction for the 90/110
performance band requirement (based on a proprietary analysis). Although we consider our
analysis confidential, I will represent that we would trade the 90/110 provision for a 5O~ fee
to the utilities for ancillary services anytime. Therefore , our price would be 57 $/MWh in
Idaho Power's territory, not far above the average RFP Price. I suspect most other PURPA
developers would also make this trade.
Since the price is about the same, the most important reason to keep PURPA
Contracts is that they are important for the agricultural community and rural counties. Large
projects are typically located on high ridges which tend to be owned by the federal
government.PURPA projects are primarily located on agricultural land. Wind projects
uniquely coexist with agriculture. They take up only a couple of percent of the land and all
of the original agricultural uses of the land continue. As for counties, almost 7O~ of our
revenues go to property taxes - that's 4 $/MWh. Because renewables are more capital
intensive , our taxes per kWh are far higher than fossil fuel projects. The Surrogate Avoided
Resource (SAR) only pays 1 $/MWh. So when you exclude property taxes that are going to
rural counties, our net price is effectively only 53 $/MWh.
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In every industry, there are small and large competitors. Small companies survive by
finding projects that big companies overlook. Since there is little price difference, Idaho
should continue with both paths. It is always wise to avoid a concentration of risk. The
mortality of wind projects during development, like all power projects, is pretty high. You
never know when something like habitat for the sage grouse or transmission constraints will
eliminate one of the few large projects. It diversifies risk to have many small developers
working to beat fossil fuels. As long as there are fossil fuelled resources in a utility
generation expansion plan, there is a societal need and federal mandate to give renewable
energy projects access to the market. PURPA is about renewables competing with fossil
fuels, not with each other.
What would prevent the losing RFP projects from simply reforming into
PURPA projects?
Now this is a legitimate concern. If it is in the public interest to prevent this, then
there is a solution. There is already a federal prohibition against two projects being within
mile of each other with common ownership. Developers can work around this by using two
independent owners. To make this rule more effective, the rule needs to be applied to the
developer. This can be accomplished by simply adding a clause into the PURPA Contracts
requiring a representation that the Project is not within 1 mile of any other project with a
PURPA Contract which has been developed under common control by the same developer
and linking the representation to a default. Although it seems like this can also be worked
around, it probably would be very effective. Financing sources would not sign on to such a
contract without extensive due diligence on this issue since it could default the power
contract. Although this is discriminating between QFs, Idaho is already doing that with the
size limit.
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GRANDFATHERING
Idaho Power recommends grandfathering a project which had substantially
completed its negotiations with Idaho Power before they started refusing to sign
contracts. Did you want to comment on that?
Yes, I would simply like to point out that Idaho Power's contract doesn t really require
any negotiations. Using the standard of "substantial completion" penalizes developers that
were following a disciplined approach to developing their projects and relied upon the long
term commitment of Idaho Power and the IPUC to PURPA wind development. These
developers avoided wall papering the Commission with power contract approvals for
infeasible projects. This was supposed to be about market access, it wasn t supposed to be
a race. There are certainly better ways to handle grandfathering.
RECOMMENDATIONS
What changes would you suggest to improve the PURPA contracting process?
I think the wind industry was being very responsible about requesting PURPA
Contracts. The projects that have been approved , if there are no major transmission
problems, should be good. However, now that Idaho Power has asked for a suspension
the credibility of the process has been destroyed and everyone with any chance is flying
through the window. Clearly it is in everyone s interest to restore the credibility of the
process and the projects. I believe this can be done without suspending access to PURPA
Contracts by providing some guidance from the Commission.
I think three things need to be done to make demand for the contracts more
manageable. First, the Commission should give some guidance regarding out-of-state
projects. My understanding is that Idaho Power s position is that they do not charge
wheeling to out-of-state projects that connect to their network. PURPA rights exist at the
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point of interconnection. A project in Oregon does not have the right to sell its power in
Idaho without making physical delivery here. Therefore , even if the Oregon connection is
with Idaho Power, they don t need to wheel it for free. In fact, it may be against the FERC
open transmission rules to do so. We are active in Oregon, so I can say that it is highly
unlikely that a project could economically sell power under the Idaho Published Prices if it
had to pay wheeling charges. By focusing on projects in Idaho, the Commission preserves
the economic benefits for Idaho s farmers, ranchers and county governments.
Second, there needs to be an entry fee for PURPA Contracts. Like anything else
that is free, it will be oversubscribed by projects that may have no chance of success. This
is detrimental to both the wind industry and utility planning. The issue is to find some way of
making this self administering so neither the Commission or Idaho Power are put in a
position to have to evaluate a project's chances for success. I suggest that no PURPA
Contracts be sign~d until the project makes its deposit for a Transmission System Impact
Study. By this point the Transmission Feasibility Study is complete and the developer
knows if it has an economic interconnection and path. For a good project, this is a
necessary step anyway, so it is not an extra expense. For a questionable project, it may be
enough to stop a frivolous request for a contract.
Third, as I pointed out earlier, large projects should be discouraged from bypassing
the RFP route by extending the one mile limit to included common development. This will
also help spread the PURPA contracts over a wider number of projects and sites.
Besides these recommendations, I would also like to suggest that the Commission
indicate its support for paying 5% of the Posted Price to utilities in lieu of the 90/110
performance band. The band is really an inefficient mechanism that provides little valuable
information. The 5% fee would be a better use of funds. The Commission would not need
to modify it's previous order. Utilities are not required to follow a strict contract form and
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may be encouraged to negotiate this alternative with the Commission s guidance. As I said
I believe this would be the preferred option for most developers.
You ve been ranting for an awfully long time. Does this finally conclude your
remarks?
Yes it does.
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Direct Testimony
Glenn Ikemoto
Case No. IPC-05-
Exhibit 1
Comparison of Judith Gap, Montana
And Idaho RFP Prices
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Ikamata, Direct
Exhibit 1
COMPARISON OF JUDITH GAP AND IDAHO WIND ECONOMICS
Montana Idaho
Project Judith Gap RFP Type
Assumptions
Year of Construction 2005 2006
Wind Classification Class 6 Class 5
Class Avg Wind Speed at 50 m (mph)18.17.
Terrain Rolling Plain Ridge Top
Shear Factor (Note 1)
Hub Height (m)
Wind Speed at 80 m (mph)20.18.
Elevation (ft)500 000
Wind Speed at Hub Height (mph)20.18.
(speed at 50m * (80m/50m) " shear factor)
Base Price 31.55.
Adjustment to 2005 $5Oib (1.38)
Less Property Taxes -6.(3.60)
Comparable Price (2005 Levelized)31.50.
Energy Production Adjustments
Lower Wind Speed in Idaho (at 80 m)12.
Effect n Ener Estimate
Convert Speed to Energy (Note 2)19.
Higher Altitude in Idaho (Note 3)0oib per 1000 I
Higher Array Losses in MT (Note 4)0oib
Total Energy Difference 17.2Oib (8.59)
41 .44
23.5OkImplicit Project Cost Difference
Adjusted Price 31.31.
RESULTS
The entire difference in price between Judith Gap and an Idaho RFP project can be explained by
a hypothetical 23.5% project cost increase between 2005 and 2006 (well within expectations),
17% more energy at Judith Gap, a property tax pass through and an adjustment to base year $.
Notes:
(1) Shear factors are typical values for ridge top and open plain sites(2) The ratio of the change in energy production due to a change in wind speed is site specific. The assumption of 1.
is based on side-by-side case scenarios
(3) losses due to air density = 3% per thousand feet with rated power (no loss) 1/3 of time; net loss = 2% per thousand fel
(4) Educated guess - assumes 5% loss per row for three rows; row performance 100%,95%,90%; average = 95%.
CERTIFICATE OF SERVICE
I hereby certify that on the 15 day of July, 2005, true and correct copies of the
PETITION TO INTERVENE OF ENERGY VISION LLC and the DIRECT TESTIMONY
OF GLENN IKEMOTO were delivered to the persons on the attached SeNice List via the
method of seNice noted.
ft--d
/"
lenn Ikemoto
Principal
EnVision Systems , LLC
SERVICE LIST
PETITION TO INTERVENE and the DIRECT TESTIMONY OF GLENN IKEMOTO
Via Overni ht and courtes
Jean Jewell
Commission Secretary
Idaho Public Utilities Commission
427 W. Washington St
Boise, ID 83702-5983
Via Fax (and courtesy email where possible)
Bart Kline
Monica Moen
Idaho Power Company
[phone]
mmoen(g)idahopower .com
Richard L. Storro
Director, Power Supply
Avista Corp.
[phone]
dick. storro(g) avi stacorp. com
R. Blair Strong
Paine, Hamblen et al
[phone]
blair .strong(g)pai neham blen.com
Dean J. Miller
McDevitt and Miller
[phone]
joe(g)mcdevitt-miller.com
Peter Richardson
[phone]
peter(g) richardsonandol eary. com
William J. Batt
John R. Hammond
Batt & Fisher
[phone]
wjb(g)battfisher.com and jrh(g)battfisher.com
Via U.S. Mail
Jared Grover
Cassia Wind LLC
3635 Kingswood Dr.
Boise, ID 83704-4322
Mike Heckler
Windland
[phone]
mheckler(g)windland.com
Lisa Nordstrom
Pacificorp
[phone]
isa. nordstrom(g) pacificorp.com
Bob Lively
Pacificorp
[phone]
bob.lively(g)pacificorp.com
William Eddie
Advocates for the West
[phone]
billeddie(g)rmci. net
David Hawk
R. Simplot
[phone]
dhawk(g)simplotcom
R. Scott Pasley
R. Simplot
[phone]
spasley(g)simplotcom
Troy Gagliano
Renewable Northwest Project
503-223-4554
renewabl es(g) rnp. org
Armand Eckert
Magic Wind LLC
716-B East 4900 North
Buhl , ID 83316