20070927Answer to Motion to Compel.pdf

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IDAHO~POWER~
An IDACORP Company
Barton L. Kline
Senior Attorney
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September 26, 2007
Jean D. Jewell, Secretary
Idaho Public Utilities Commission
472 West Washington Street
P. O. Box 83720
Boise , Idaho 83720-0074
Re:Case No. IPC-07-
Exergy Development Group of Idhao, LLC v.
Idaho Power Company
Dear Ms. Jewell:
Please find enclosed for filing an original and seven (7) copies of Idaho Power
Answer to Exergy s Motion to Compel Idaho Power to Retain Exergy s Projects in its
Interconnection Queue and to Cmpel a Refund of Deposits Posted by Exergy.
I would appreciate it if you would return a stamped copy of this transmittal letter in
the enclosed self-addressed, stamped envelope.
Barton L. Kline
BLK:sh
Enclosures
O. Box 70 (83707)
1221 W. Idaho St.
Boise, ID 83702
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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]
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Attorney for Idaho Power Company
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
vs.
EXERGY DEVELOPMENT GROUP OF
IDAHO, LLC CASE NO. IPC-07-
Respondent.
IDAHO POWER'S ANSWER TO
EXERGY'S MOTION TO COMPEL IDAHO
POWER TO RETAIN EXERGY'
PROJECTS IN ITS INTERCONNECTION
QUEUE AND TO COMPEL A REFUND
OF DEPOSITS POSTED BY EXERGY
Petitioner
IDAHO POWER COMPANY
COMES NOW Idaho Power Company ("Idaho Power" or the "Company ) and
hereby answers the Motion of Exergy Development Group of Idaho , LLC ("Exergy ) in
which Exergy requested the Commission to issue its order as follows:
Prohibiting Idaho Power from removing any of Exergy s projects that are the
subject of its Complaint from its interconnection queue; and
Requiring Idaho Power to comply with Schedule 72 by providing Exergy with
the costs for interconnecting its QF projects without first requiring a deposit; and
IDAHO POWER'S ANSWER TO EXERGY'S MOTION TO COMPEL IDAHO POWER TO RETAIN
EXERGY'S PROJECTS IN ITS INTERCONNECTION QUEUE AND TO COMPEL A REFUND OF DEPOSITS
POSTED BY EXERGY -
That Idaho Power refund those deposits already posted pending receipt by
Exergy of a complete cost breakdown for interconnecting its projects to Idaho Power
electrical system.
In its Motion , Exergy also proposed alternative measures to be implemented if the
Commission did not grant the above-described three requests.
Exergy s Motion should be dismissed because Idaho Power s requests that Exergy
provide deposits comply with the interconnection process set out in Schedule 72. The
Commission should also dismiss Exergy s Motion if the Commission finds that Exergy is
using the Complaint process to obtain an advantage over other QF developers with
competing interconnection requests.
Idaho Power s Interconnection Process Ensures Equal Treatment for All
Interconnection Customers
Schedule 72 is the Commission approved tariff that governs Idaho Power
QF interconnections.Idaho Power voluntarily filed Schedule 72 in 1990 and the
Commission approved Schedule 72 in 1991. From the outset, the purpose of Schedule 72
has been to ensure that interconnection costs for QFs seeking to sell their energy to Idaho
Power are assessed in a consistent manner that (1) recovers all of Idaho Power
interconnection costs from QF developers; (2) protects customers from absorbing the costs
of abandoned QF projects; and (3) as required by PURPA, does not discriminate against
QFs. Schedule 72 apparently has been successful in fulfilling its purpose because, to
Idaho Power s recollection , this is the only formal Complaint the Company has ever
received claiming that the Company was failing to implement Schedule 72 correctly.
IDAHO POWER'S ANSWER TO EXERGY'S MOTION TO COMPEL IDAHO POWER TO RETAIN
EXERGY'S PROJECTS IN ITS INTERCONNECTION QUEUE AND TO COMPEL A REFUND OF DEPOSITS
POSTED BY EXERGY - 2
Much more recently (2000-2004), the Federal Energy Regulatory
Commission ("FERC") decided that in order to promote competition and non-utility
generation it would establish detailed procedures to manage competitive requests to use
the interstate transmission system and for recovery of costs from transmission system
users. FERC established detailed procedures for studying and allocating transmission
capacity and established the queue system for managing transmission requests. (FERC
Order No. 885 et seq.
).
In Order 2003 et seq.FERC established detailed rules governing
how generating projects interconnect and utilize utility-owned transmission facilities and
how the cost of interconnection would be recovered from generation developers. FERC
also established a separate queue system for interconnection requests.FERC'
interconnection study and queue management requirements are mandatory and are filed
with FERC as a part of Idaho Power s Open Access Transmission Tariff ("OATT").
To assure compliance with FERC's regulations , and maintain comparable
treatment between QF and non-QF generation developers, Idaho Power applies the FERC
rules for managing priority in the interconnection queue and processing all interconnection
requests , including QF requests for interconnection under Schedule 72. Applying the
FERC procedures to all interconnection requests, including QFs , establishes a uniform
consistent process for analyzing transmission interconnection requests. It provides QFs
with certainty as to the processing times and the rules that will be followed in processing
the requests for interconnection.
To assist the Commission in its understanding of the interconnection process
Idaho Power followed with Exergy, it is necessary to briefly describe the process FERC
requires for studying interconnection requests and establishing the costs of interconnection
IDAHO POWER'S ANSWER TO EXERGY'S MOTION TO COMPEL IDAHO POWER TO RETAIN
EXERGY'S PROJECTS IN ITS INTERCONNECTION QUEUE AND TO COMPEL A REFUND OF DEPOSITS
POSTED BY EXERGY - 3
facilities. FERC rules require that each interconnection application go through a four step
process.
(a)Application - the developer provides a general description of the project and
its location. Application requires payment of an initial refundable deposit in the amount of
000.00 for a small generation interconnection and $10 000.00 for a large generation
interconnection.
(b)Feasibility Study - this is a preliminary evaluation of the facilities, equipment
and cost interconnecting the generating project the Company
distribution/transmission facilities at the developer s chosen physical location. The
developer signs a Feasibility Study Agreement but no deposit is required for a Feasibility
Study as the Application deposit collected in step (a) is applied to cover the expenses
Idaho Power will incur performing the Feasibility Study. At the conclusion of the Feasibility
Study the generation developer is given a written Feasibility Study Report that among other
things, presents a list of facilities and a non-binding good faith estimate of cost
responsibility. Based on the Feasibility Study Report, the developer can then decide if it
wants to stay in the interconnection queue and continue with the design and cost
estimation process. If so, a System Impact Study is conducted.
(c)System Impact Study - the system impact study requires execution of a
System Impact Study Agreement and the posting of a deposit sufficient to cover Idaho
Power s cost of performing the System Impact Study. The cost to perform the System
Impact Study differs for each project based on distribution and transmission facilities that
are impacted by the proposed generation interconnection. These studies range in cost
from a few thousand dollars to $10,000.00. The System Impact Study produces an
IDAHO POWER'S ANSWER TO EXERGY'S MOTION TO COMPEL IDAHO POWER TO RETAIN
EXERGY'S PROJECTS IN ITS INTERCONNECTION QUEUE AND TO COMPEL A REFUND OF DEPOSITS
POSTED BY EXERGY - 4
evaluation of the impact of the proposed interconnection on the reliability of the
transmission system and a non-binding good faith estimate of cost responsibility which is
given to the developer in a written System Impact Study Report.
If the developer, after reviewing the System Impact Study Report concludes that it
still desires to remain in the queue and proceed with design and engineering studies, the
developer and the Company enter into a contract for a Facility Study.
Facility Study - the Facility Study Agreement requires the payment of a
deposit to cover the cost of developing the final design specifications. Idaho Power
experience in performing Facility Studies demonstrates that the engineering and design
costs make up approximately 10% of the total interconnection costs. For example , if an
interconnection will cost $2 million , the cost of engineering and transmission design for that
specific interconnection would be approximately $200 000. Idaho Power caps its deposit
requests at $100 000. The Facility Study provides a highly refined estimate of the
equipment, engineering, procurement and construction work needed to implement the
conclusions of the System Impact Study to physically and electrically connect the
interconnection project. Construction options are also provided during this time. If long
lead-time items need to be ordered in time for Construction , the Company will request
funding by the developer to cover these equipment costs.
The intent of this four stage process is to allow the generation project developer to
obtain increasingly refined estimates of the costs of interconnecting its project, and to
provide an opportunity to withdraw anytime they choose. In any case , Idaho Power will
reconcile all deposits against work done for the generation project , and the project
IDAHO POWER'S ANSWER TO EXERGY'S MOTION TO COMPEL IDAHO POWER TO RETAIN
EXERGY'S PROJECTS IN ITS INTERCONNECTION QUEUE AND TO COMPEL A REFUND OF DEPOSITS
POSTED BY EXERGY - 5
developer will receive a refund of any monies that have not been actually spent, or an
invoice for amount(s) due for engineering and design of its' interconnection facilities.
Collecting Deposits for Interconnection Studies is Permitted Under Schedule 72
In its Motion Exergy alleges that Idaho Power is unlawfully requiring Exergy to
provide cash deposits because Schedule 72 does not authorize the collection of deposits.
Exergy s allegation is inconsistent with the facts and the provisions of Schedule 72. The
pertinent portion of Schedule 72 reads as follows:
PAYMENT FOR INTERCONNECTION FACILITIES
Unless specifically agreed otherwise by written
agreement between the Seller and the Company, an initial cost
estimate of Company-owned interconnection Facilities will be
provided to the Seller.
Payment of the estimated cost will be required prior to
the Company s ordering, installing, modifying, upgrading, or
performing in any other way work associated with the
Interconnection Facilities.
Upon completion of the Company-owned
Interconnection Facilities , the actual costs will be reconciled
against the estimated cost previously paid by the Seller and
the appropriate billing or refund will be processed.
The Company reserves the right to collect additional
costs from the Seller for any additional Company equipment
modifications , or upgrades the Company deems necessary to
operate and maintain a safe, reliable electrical system as a
result of the interconnection of the Seller s Generation Facility
to the Company s system.
Exergy argues that Schedule 72 imposes a two-step process on Idaho
Power s ability to collect a deposit for interconnection expense. (Brief p. 4). Step one
requires that the Company provide an initial cost estimate of the interconnection facilities
that will be required. Exergy argues that without satisfying step one, providing the cost
IDAHO POWER'S ANSWER TO EXERGY'S MOTION TO COMPEL IDAHO POWER TO RETAIN
EXERGY'S PROJECTS IN ITS INTERCONNECTION QUEUE AND TO COMPEL A REFUND OF DEPOSITS
POSTED BY EXERGY - 6
estimate, the language of Schedule 72 precludes the Company from proceeding to step 2
requesting any deposit or prepayment of the estimated cost of performing interconnection
studies.
The phrase "payment of the estimated costs" necessarily
assumes that there IS an estimate of the costs. Schedule 72
clearly requires Idaho Power, prior to assessing any costs to
the developer, to provide the developer with an estimate of the
costs of "ordering, installing, modifying, upgrading or
performing in any other way, work associated with the
interconnection facilities." (Brief in Support of Motion p. 8).
Exergy seems to be under the mistaken impression that Idaho Power has
never provided Exergy with an initial estimate of the costs of the interconnections for each
of the generation project at issue in this case. Attached to this Answer as Exhibits 1
through 5 are the pertinent pages from the Generator Interconnection Feasibility Study
Reports provided to Exergy for each of the projects at issue in this proceeding. Exhibits 1-
5 show that Idaho Power has provided an initial estimate of the cost of interconnecting
each of Exergy s generation projects at issue in this proceeding.
Because Idaho Power has satisfied step 1 , providing an initial cost estimate
Schedule 72 authorizes the Company to proceed to step 2 , requesting a deposit for
interconnection studies. Schedule 72 provides "Payment of the estimated cost will be
required prior to the Company s ordering, installing, modifying, upgrading or performing in
any other way, work associated with the interconnection facilities.
A literal reading of Schedule 72 indicates that once Exergy has received the
initial cost estimate for its QF projects , Idaho Power could have required Exergy to pay
100% of the estimated cost of interconnection before the Company performed any
additional interconnection cost studies or performed any other work relating to the Exergy
IDAHO POWER'S ANSWER TO EXERGY'S MOTION TO COMPEL IDAHO POWER TO RETAIN
EXERGY'S PROJECTS IN ITS INTERCONNECTION QUEUE AND TO COMPEL A REFUND OF DEPOSITS
POSTED BY EXERGY - 7
projects interconnection. However, Idaho Power did not require Exergy to post the full
100%. The Company continued with the 4 step study process described above and
requested that Exergy post refundable deposits for subsequent studies. Idaho Power
request to Exergy is consistent with the process Idaho Power follows for all interconnection
requests. Idaho Power only asks for advance payment for studies and facilities as
necessary to minimize the risk that the Company will not be able to recover its costs from
the developer if the developer changes its mind about moving forward with the project.
10.In essence , the Company requests that estimated interconnection costs be
paid in installments. The early installments are for the cost of performing transmission
engineering and design studies. Later installments might require advance payment for
long lead time equipment.Final installments would be due prior to the Company
commencing actual construction and installation of facilities.
11.Nothing in Schedule 72 prohibits the Company from requesting that payment
of the estimated cost of interconnection be made in installments. In fact, requesting that
QFs pay interconnection costs in installments, based on the actual costs Idaho Power will
incur as each phase of the work is performed , is consistent with prior Commission orders.
In 2002 , the Commission approved certain modifications to Schedule 72. The Commission
approved the Company s proposed modifications in Order No. 29092 , issued in Case No.
IPC-01-31. In that Order the Commission stated:
Regarding interconnection cost responsibility, we find
that it is important for the tariff to explicitly state that all
interconnection costs will be borne by the customer-generator.
If interconnection requires more than the customer-furnished
standard equipment it is the customer-generator
responsibility to bear those additional interconnection
expenses. We appreciate the QF's desire for certainty. We
IDAHO POWER'S ANSWER TO EXERGY'S MOTION TO COMPEL IDAHO POWER TO RETAIN
EXERGY'S PROJECTS IN ITS INTERCONNECTION QUEUE AND TO COMPEL A REFUND OF DEPOSITS
POSTED BY EXERGY - 8
put the Company on notice that should it abuse its discretion in
interconnect matters and thwart the development of non-utility
generation, the Commission will entertain a complaint and
revisit the issue.
Idaho Power believes that allowing QFs to "pay as you go" and only take deposits as costs
are expected to be incurred is consistent with the Commission s mandate in Order No.
29092 that Idaho Power manage the interconnection process under Schedule 72 in a way
that is fair to QF developers.
The FERC Interconnection Manaqement Process is Compatible With Schedule 72
12.In its Motion , Exergy concludes , without citing legal or factual bases , that
Idaho Power s practice of using FERC's rules for processing interconnection requests is
inconsistent with Schedule 72.
The fragrant (sic) and blatant disregard of this Commission
exclusive jurisdiction" over interconnections in favor of a
foreign tribunal's rules threatens the very integrity of this
Commission s orders and authority over its regulated utilities.
Permitting Idaho Power to unilaterally disregard its Schedule
72 would set a dangerous precedent. This is precisely the type
of self-serving deviation from publish rates and schedules that
the filed rate doctrine prohibits. Even if the result appears
harsh, the filed rate doctrine does not permit a utility to simply
ignore its tariffs. (Brief in Support of Motion pp. 6-7).
Exergy s spirited defense of the Commission s authority is unnecessary. Idaho Power is
not relying on FERC's authority as justification for collecting deposits from Exergy. The
Company does not need to rely on FERC's authority. The plain language in Schedule 72
provides the Company will all the authority it needs to collect deposits to protect customers.
The benefit of applying FERC's interconnection study process is the uniformity and
consistency that it provides. Utilizing FERC's four stage interconnection study process and
the FERC's rules for managing the QF interconnection queue is completely compatible and
IDAHO POWER'S ANSWER TO EXERGY'S MOTION TO COMPEL IDAHO POWER TO RETAIN
EXERGY'S PROJECTS IN ITS INTERCONNECTION QUEUE AND TO COMPEL A REFUND OF DEPOSITS
POSTED BY EXERGY - 9
consistent with the terms of Schedule 72. The intent of both FERC's interconnection
process and the interconnection process in Schedule 72 are identical. They both are
intended to provide generation developers with (1) interconnection cost estimates they can
use to assess the viability of their respective generation projects; and (2) to increase the
likelihood that Idaho Power will be able to collect the costs it incurs for interconnecting
independent generation projects including the costs of engineering and design of
interconnection facilities.
The Filed Rate Doctrine is Irrelevant Under the Facts of this Case
13.A significant portion of Exergy s brief is devoted to a discussion of the Filed
Rate Doctrine.Idaho Power does not understand how Exergy concludes that the
Company s requests for deposits from Exergy violate the filed rate doctrine. If it is Exergy
position that Idaho Power has never given Exergy an estimate of the cost
interconnection its projects, and therefore the filed rate doctrine precludes the Company
from requiring a deposit, Exergy is incorrect on the facts. As Exhibits 1-5 demonstrate
Idaho Power has in fact provided Exergy with initial interconnection cost estimates and is in
full compliance with Schedule 72 even as interpreted by Exergy. As a result the filed rate
doctrine would not be applicable to the facts in this case.
14.If Exergy is arguing that the filed rate doctrine precludes Idaho Power from
relying on FERC's interconnection queue management rules as support for its request for
deposits from Exergy, again, the facts do not support Exergy s assertions. Idaho Power
derives its authority to request deposits from Exergy on the Commission-approved terms
and conditions of Schedule 72 , not from the FERC's rules. The FERC rules are consistent
IDAHO POWER'S ANSWER TO EXERGY'S MOTION TO COMPEL IDAHO POWER TO RETAIN
EXERGY'S PROJECTS IN ITS INTERCONNECTION QUEUE AND TO COMPEL A REFUND OF DEPOSITS
POSTED BY EXERGY - 10
with Schedule 72 but the Company is not relying on them as support for its authority to
collect deposits and/or prepayments for interconnection study costs.
15.In its filed rate doctrine discussion in its Brief, Exergy points out that the word
deposit" is not used in Schedule 72. Exergy is correct in that regard. But in reading
Schedule 72 , it is clear that Exergy s reliance on the lack of the word "deposit" as support
for its filed rate doctrine claim is misplaced. Under Schedule 72 , Idaho Power is permitted
to recover all of the costs of interconnecting a QF generation facility to the Company
system. Under Schedule 72 Idaho Power can require payment of the estimated cost of
interconnecting the QF generation facility prior to the Company performing any work
associated with the interconnection facilities. Nothing in Schedule 72 precludes Idaho
Power from taking payments for interconnection facilities in installments. Schedule 72
further provides that upon completion of the construction of the interconnection facilities
the actual cost will be reconciled against the estimated cost previously paid by the Seller
and the appropriate billing or refund will be processed. Because the QF is making
payments prior to performance of the actual work, calling this payment a "deposit" or an
installment payment" or an "advance" or a "prepayment" does not change the fact that
Idaho Power is authorized under Schedule 72 to collect monies in anticipation of
performing work associated with the Seller s interconnection and is authorized to apply the
early payment to the final bill.
16.Exergy s failure to acknowledge the fact that any payments its makes will be
applied to actual expenditures incurred by Idaho Power, is telling. A pre-payment to be
applied to a final bill is a "deposit". Idaho Power does not believe that any reasonable
reading of Schedule 72 would support a requirement that Idaho Power perform time-
IDAHO POWER'S ANSWER TO EXERGY'S MOTION TO COMPEL IDAHO POWER TO RETAIN
EXERGY'S PROJECTS IN ITS INTERCONNECTION QUEUE AND TO COMPEL A REFUND OF DEPOSITS
POSTED BY EXERGY - 11
consuming and expensive interconnection studies without first requiring that Exergy
provide some security that the Company could utilize to offset costs if Exergy decides not
to proceed with the project. To interpret the filed rate doctrine to allow a developer to avoid
providing security for its performance simply because the word "deposit" is not used in
Schedule 72 would be the ultimate triumph of form over substance.
It is Unfair to Allow Exer~1V to Maintain its Position in the Generation
Interconnection Queue Without Followina the Rules
17.The second item in Exergy s Motion is a request that the Commission require
Idaho Power to provide Exergy with estimates of interconnection costs for Exergy s QF
projects without first requiring a deposit. Exergy argues that this request is reasonable
because Idaho Power has not provided Exergy with any interconnection cost estimate so it
is precluded under Schedule 72 from collecting any deposits. As Idaho Power has noted
previously, Exergy is not correctly stating the facts. But even if it was, fundamental fairness
dictates that the Commission deny Exergy s request. Since 2000, Idaho Power has
received more than 200 requests for interconnection. In each instance , Idaho Power has
requested , and received deposits to offset engineering and design expense and to ensure
that customers have some measure of protection from losses if a developer decides to
abandon its generation project in mid-stream. Exergy s request that it be permitted to
obtain cost estimates for interconnecting its QF projects without first paying a deposit
would certainly be discriminatory and preferential treatment vis-a.-vis all other generation
project developers maintaining a position in Idaho Power s interconnection queue.
18.This potential for discrimination is exacerbated by the fact that all but one of
Exergy s projects at issue in this Complaint are included in the Twin Falls cluster which is
IDAHO POWER'S ANSWER TO EXERGY'S MOTION TO COMPEL IDAHO POWER TO RETAIN
EXERGY'S PROJECTS IN ITS INTERCONNECTION QUEUE AND TO COMPEL A REFUND OF DEPOSITS
POSTED BY EXERGY - 12
the subject of the Commission s recent Order No. 30414 in Case No. IPC-06-, the
Cassia Windfarm case. As the Commission knows from that proceeding, the costs of
interconnection for all of the participants in the Twin Falls cluster are dependent on
whether or not other projects ahead of them in the queue proceed to development. By
remaining in the Twin Falls' queue without providing deposits in the same manner that
other queue participants have provided them, the Exergy projects have created uncertainty
and have imposed a financial disadvantage on the other participants in the queue. The
Commission should not facilitate this kind of gamesmanship.
ExerQV Should be CharQed the Correct Interconnection Deposit Amounts
19.In its Alternative Motion , Exergy argues that even if the Commission
ultimately determines that Idaho Power has acted in accordance with Schedule 72 and has
appropriately requested that Exergy pay deposits for interconnection costs, that Idaho
Power should not be permitted to charge the amount Idaho Power has requested from
Exergy. Exergy argues that it is entitled to pay the amount that Idaho Power erroneously
included in the sample study agreements posted on its website. The Company has
acknowledged that as result of a clerical error, the Company s example study
agreements posted on its website contained incorrect deposit amounts. As the Company
noted in its Answer to the Complaint, the example agreements have now been corrected
and the erroneous deposit amounts have been removed from the example agreements.
20.Exergy s argument that it should be permitted to rely on Idaho Power
FERC-required website posting is simply another part of its effort to "game" the system in
1 It should be noted that Exergy has provided Feasibility Study deposits and some System Impact Study
deposits in the past. It is only recently that it has decided not to pay the higher deposits required to proceed
further in the interconnection study process.
IDAHO POWER'S ANSWER TO EXERGY'S MOTION TO COMPEL IDAHO POWER TO RETAIN
EXERGY'S PROJECTS IN ITS INTERCONNECTION QUEUE AND TO COMPEL A REFUND OF DEPOSITS
POSTED BY EXERGY - 13
order to gain an advantage over other QF developers in the interconnection queue. Other
developers have not expressed confusion as to what their current deposit amounts should
be.
21.Exergy s argument is at odds with its prior assertions regarding the
Application of Schedule 72 to Idaho Power s interconnections with QFs. Previously,
Exergy argued that application of the FERC process , which includes the requirement that
sample study agreements be posted on the Company s website, could not, as a matter of
law , be binding on QF projects like Exergy s projects. But here , Exergy argues that
postings on the FERC-required website are binding on Idaho Power. Exergy cannot have it
both ways.
ExerQV Misinterpreted Idaho Power s Reference to Credit RatinQ
22.In its Motion , Exergy is critical of Idaho Power s references to credit rating in
the Company s discussion of why it requires deposits for interconnection studies. In light
Exergy s response in its Brief it is apparent that Idaho Power was not as clear as it should
have been in its discussion in its Answer to the Complaint of the role that credit plays in
determining requests for deposit for interconnection studies. It was Idaho Power s intention
in referring to credit rating in its Answer to the Complaint to make sure Exergy and the
Commission understood that an interconnection customer with a good credit rating would
not have to post cash deposits for interconnection studies. It is true that under the
Commission s prior orders regarding security for QF projects, the Company cannot require
a QF developer to demonstrate good credit or provide any credit information to the
Company. However, that does not mean that a QF developer like Exergy could not, if it
has good credit, avoid the need to provide Idaho Power with cash deposits for
IDAHO POWER'S ANSWER TO EXERGY'S MOTION TO COMPEL IDAHO POWER TO RETAIN
EXERGY'S PROJECTS IN ITS INTERCONNECTION QUEUE AND TO COMPEL A REFUND OF DEPOSITS
POSTED BY EXERGY - 14
interconnection studies.
Idaho Power has Provided Exerav With Reasonable Cost Verification
23.In its Motion Exergy urges the Commission to require Idaho Power to "provide
Exergy with a detailed explanation and accounting of how the Company has spent all
deposited monies to date.
24.For the Commission s information , for each generation interconnection
project, QF or otherwise , for which a deposit is taken, Idaho Power establishes a separate
accounting work order. As interconnection studies proceed , charges for engineering,
design services and materials are charged to the work order and the deposit amount is
applied to those charges.
25.For all of the Exergy projects that are the subject of the Complaint, Idaho
Power has provided Exergy with a time and materials invoice. At Exergy s request, Idaho
Power has also provided Exergy with additional backup data in support of the invoices.
Idaho Power is uncertain as to how much more detail it can provide Exergy above and
beyond the detail that has already been provided to Exergy. Nevertheless , Idaho Power is
willing to work with Exergy to see if it can address Exergy s desire for more information.
However, as previously noted , Idaho Power is concerned that this portion of Exergy
Complaint could be used as an excuse to further delay Exergy s payment of the required
deposits thereby allowing Exergy to maintain its position in the interconnection queue to
the disadvantage of other queue participants who have provided the deposits requested by
the Company.
26.To avoid even the appearance that Exergy is "gaming" the complaint
process, Idaho Power believes that it would be appropriate for the Commission to order
IDAHO POWER'S ANSWER TO EXERGY'S MOTION TO COMPEL IDAHO POWER TO RETAIN
EXERGY'S PROJECTS IN ITS INTERCONNECTION QUEUE AND TO COMPEL A REFUND OF DEPOSITS
POSTED BY EXERGY - 15
Exergy to make the required deposit payments. If a subsequent review of the available
cost information Exergy desires to review, reveals that Idaho Power somehow requested
deposit payments prematurely, then Exergy should be paid interest on such amounts.
Again, it is important to remember that these payments are deposits and will ultimately be
applied to costs the Company incurs to interconnect Exergy s QF projects.
Conclusion
For all the reasons set forth above , the Commission should issue its order as
follows:
Denying Exergy s motion for an order compelling Idaho Power to retain
Exergy s projects in its interconnection queue. Instead the Commission shall issue its order
authorizing Idaho Power to remove Exergy s projects from the interconnection queue
unless Exergy posts the required deposits within a reasonable period of time. Idaho Power
suggests fou rteen (14) days from the date of the Commission s order would be reasonable;
Denying Exergy s other requests for relief contained in both the Motion and
the Alternative Motion;
With respect to those portions of Exergy s Motion in which it demands that
the Company provide additional accounting information and cost breakdowns for how
Idaho Power has spent the monies Exergy has previously deposited with the Company,
Idaho Power requests that the Commission order Exergy to first make the required deposit
payments and if the Commission subsequently determines that Idaho Power requested
deposit payments unreasonably or prematurely, that Exergy be paid interest on such
amounts.
IDAHO POWER'S ANSWER TO EXERGY'S MOTION TO COMPEL IDAHO POWER TO RETAIN
EXERGY'S PROJECTS IN ITS INTERCONNECTION QUEUE AND TO COMPEL A REFUND OF DEPOSITS
POSTED BY EXERGY - 16
Respectfully submitted this 02!rf1,day of September 2007.
~t\
BARTON L. KLINE
--..
Attorney for Idaho Power Company
IDAHO POWER'S ANSWER TO EXERGY'S MOTION TO COMPEL IDAHO POWER TO RETAIN
EXERGY'S PROJECTS IN ITS INTERCONNECTION QUEUE AND TO COMPEL A REFUND OF DEPOSITS
POSTED BY EXERGY - 17
CERTIFICATE OF MAILING
I HEREBY CERTIFY that on the 02&#day of September 2007 , I served a true
and correct copy of the within and foregoing 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
) U.S. Mail , Postage Prepaid
(X) Hand Delivered
) Overnight Mail
) Facsimile
) Email: scott.woodburv(g) puc.idaho.qov
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
(X) Email: peter(g) richardsonandolearv.com
James 1. Carkulis
802 W. Bannock street
Boise , Idaho 83702
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LL-
BARTON L. KLINE
CERTIFICATE OF SERVICE
BEFORE THE IDAHO PUBLIC UTiliTIES
COMMISSION
CASE NO. IPC-O7-
IDAHO POWER COMPANY
ATTACHMENT
GENERA TOR INTERCONNECTION
FEASIBILITY STUDY
for integration of the proposed
GOLDEN VALLEY WIND PARK PROJECT
III
CASSIA COUNTY, IDAHO
to the
IDAHO POWER COMPANY ELECTRICAL SYSTEM
for
EXERGY DEVELOPMENT GROUP, LLC
the
INTERCONNECTION CUSTOMER
FINAL REPORT
January 3, 2007
1.0 Introduction
Exergy Development Group, LLC has contracted with Idaho Power Company (IPe) to perfonn a
Generator Interconnection Feasibility Study for the integration of the proposed 11.62 MW
Golden Valley Wind Park Project (project #155). The location of the project is in Idaho Power
southern Idaho service territory in sections 29 and 32 ofTllS, R22E of Cassia County. This
location starts approximately V2 mile west ofIdaho Power s existing Golden Valley substation.
This report documents the basis for and the results of this Feasibility Study for the Golden Valley
Wind Park. It describes the proposed project, the study cases used, the impact of associated
projects, and results of all work in the areas of concern.
Summary
The proposed project is an 11.62 MW wind fann consisting of seven 1.5 MW GE wind turbines.
This wind fann will interconnect with the IPC system at about 600 S. and 560 W. in Cassia
County, Idaho.
The transmission system serving this area is Idaho Power s 69 kV Golden Valley loop. With the
consideration of other proposed generation projects in the queue ahead of this project there is
adequate capacity available on the existing 69 kV transmission line in the immediate area to
serve this project. However, this study has identified limitations in the Midpoint West
transmission system to the west of this area. This study demonstrates that there is available
transmission capacity when considering other proposed generation projects ahead of this one in
the queue. Therefore, a System Impact Study will be required to detennine the transmission
upgrades needed to serve this project.
The substation serving this area is the Golden Valley (GNVY) Substation. Two feeder breakers
at GNVY Substation will have to be upgraded to connect the proposed project.
The distribution feeder serving this area is GNVY-O13. Upgrades on the feeder will be
necessary to serve this proj ect.
The estimated cost of all required upgrades is $333 000.
The existing feeder can accept up to 8.77 MV A of generation at the point of interconnection
before feeder reconductoring is required.
Scope of Interconnection Feasibility Study
The Interconnection Feasibility Study was done and prepared in accordance with Idaho Power
Company Standard Generator Interconnection Procedures, to provide a preliminary evaluation of
the feasibility of the interconnection of the proposed generating project to the Idaho Power
system. All other proposed Generation projects prior to this project in the Generator
Interconnect queue were considered in this study. A current list of these projects can be found
on the Idaho Power web site as follows:
Small Generator (~20 MW):
http://www .idahopower. com! aboutus/business/ generationfuterconnect/ generationlnterconnectcfm
Large Generator (~O MW):
http://www.oatioasis.com/ipco/index.html.
Description of Proposed Generating Project
The Golden Valley Wind Park proposes to connect to the Idaho Power distribution system for an
injection of 11.62 MW (maximum project output) using seven GE 1.5 MW wind turbines.
Description of Existing Transmission Facilities
The transmission system serving this area is Idaho Power s 69 kV Golden Valley loop. This
system serves the area south of Burley and is configured as a loop with an open point in the
middle, effectively making it two radial lines. The conductor on the affected portion of the
system is 397 ACSR, which has a continuous thennal operating rating of 71.8 MV A. With the
consideration of other proposed generation projects in the queue ahead of this project there is
adequate capacity available on this particular line to serve this project. However, the study has
identified limitations in the Midpoint West transmission system to the west of this area. This
study demonstrates that there is available transmission capacity when considering other
proposed generation projects ahead of this one in the queue. Because of these limitations
, ~
Transmission System Impact Study will be required to detennine the next upgrades required to
add this project. An existing study is attached as Appendix C. This study details the existing
system limitations and describes the improvements necessary to increase the capacity of this
system another 305 MW. However, this proposed capacity is already committed to other
proposed generation projects currently ahead of this one in the queue. The proposed study will
detennine the additional work necessary to integrate this project into the Idaho Power system.
Description of Existing Substation Facilities
The substation serving this area is Idaho Power s Golden Valley (GNVY) Substation, which is
located at 600 S. and 500 W. in Cassia County. The existing substation transfonner is a 69:12.
kV transfonner rated for 14.0 MV A. With the consideration of the size of the proposed project
there is adequate capacity in this substation to serve this project.
The feeder breaker on the feeder serving this project, Golden Valley 13 (GNVY-O13), is a
Pacific Electric (manufactured by Federal Pacific Electric) type "JCE 22" breaker designed for
600 amps continuous load current and has a maximum fault current interrupting rating of 1 0 000
amps. Initial studies indicate that there is adequate load and short circuit interrupting capability
on this breaker to add the wind park. However, these studies also indicate that the addition of the
wind park will cause the feeder breakers on the adjacent feeders, GNVY-Oll and GNVY-012, to
BEFORE THE IDAHO PUBLIC UTiliTIES
COMMISSION
CASE NO. IPC-O7-
IDAHO POWER COMPANY
ATTACHMENT 2
GENERATOR INTERCONNECTION
FEASIBILITY STUDY
for integration of the proposed
LAVA BEDS WIND PARK PROJECT
III
BINGHAM COUNTY, IDAHO
to the
IDAHO POWER COMPANY ELECTRICAL SYSTEM
for
EXERGY DEVELOPMENT GROUP, LLC
the
INTERCONNECTION CUSTOMER
FINAL REPORT
January 3, 2007
1.0 Introduction
Exergy Development Group, LLC has contracted with Idaho Power Company (IPC) to perform a
Generator Interconnection Feasibility Study for the integration of the proposed 19.92 MW Lava
Beds Wind Park Project (project #156). The proposed location of the project is in Idaho Power
eastern Idaho service ten-itory in sections 14 34 and 35 of TIS , R32E and
sections 2 and 3 ofT2S, R32E of Bingham County, Idaho. The proposed Point of
Interconnection, selected by Idaho Power for purposes of defining the scope of this study, is the
comer of800 N. and 1900 W., which is the location ofIdaho Power s existing Taber substation.
This report documents the basis for and the results of this Feasibility Study for the Lava Beds
Wind Park. It describes the proposed project, the impact of associated projects, and results of all
work in the areas of concern.
Summary
The proposed project is a 19.92 MW wind farm consisting of twelve or thirteen 1.5 MW GE
wind turbines. This wind farm will interconnect with the IPC system at about 800 N. and 1900
W. in Bingham County, Idaho.
The transmission system serving this area is Idaho Power s 46 kV system north of Pingree. With
the consideration of other proposed generation projects in the queue ahead ofthis project there is
adequate capacity available on either of the two existing transmission lines in the immediate area
to serve this project. However, this study has identified limitations in the Borah West
transmission system to the west of this area. This study demonstrates that there is available
transmission capacity when considering other proposed generation projects ahead of this one in
the queue. A System Impact Study will be required to determine the transmission upgrades
needed to serve this project.
The substation serving this area is the Haven (HA VN) substation. The Load Tap Changer (LTC)
at this substation will have to be reprogrammed to serve the proposed project.
One of the distribution feeders serving this area is HA VN-042. Initial studies indicate that this
feeder can accept up to 19.0 MW of generation as long as the wind park generates at a 0.
lagging power factor. This is required to maintain adequate voltage on the feeder during light
load conditions. A capacitor bank will also be required at the substation. If these special
operating instructions, which are described further in Section 7, can be met then HA VN-042 has
thermal capacity at the proposed point of interconnection to serve this project. Ifnot, the
required upgrades are listed in Section 8.
A generation interconnection package will be required at the point of interconnection.
Grounding requirements and other acceptability requirements are found in Appendix A.
The estimated cost of all known required upgrades is $270 000.
Scope of Interconnection Feasibility Study
The Interconnection Feasibility Study was done and prepared in accordance with Idaho Power
Company Standard Generator Interconnection Procedures, to provide a preliminary evaluation of
the feasibility of the interconnection of the proposed generating project to the Idaho Power
system. All other proposed Generation projects prior to this project in the Generator
Interconnect queue were considered in this study. A current list of these projects can be found
on the Idaho Power web site as follows:
Small Generator (~20 MW):
http://www.idahopower,com!a boutus/business/ generationInterconnect/ generationInterconnect. cfm
Large Generator (;;:20 MW):
http://www.oatioasis.comlipcolindex.html.
Description of Proposed Generating Project
The Lava Beds Wind Park proposes to connect to the Idaho Power distribution system for an
injection of 19.92 MW (maximum project output) using twelve or thirteen GE 1.5 MW wind
turbines.
Description of Existing Transmission Facilities
The transmission system serving this area is Idaho Power s 46 kV system which sources out of
Pingree Substation. Power is delivered to Pingree Substation at 138 kV, where it is transfonned
to 46 kV. From Pingree there are two 46 kV lines north to the area of the project. Line #154
from Pingree substation to Taber substation is part of the Blackfoot - Pingree 46 kV system.
The first 8 miles from Pingree to Rockford are 2/0 ACSR conductor, and the remaining 11 miles
to Taber Substation are 4/0 ACSR conductor. At 46 kV, 2/0 ACSR is rated for 22.8 MV A and
4/0 ACSR is rated for 29.7 MV A.
The second line serving the area of the wind park is line #446 from Pingree Substation to Haven
Substation. This line is built to 138 kV standards but is currently energized at 46 kV. The
conductor on this line is 397 ACSR, which has a continuous thennal rating of 47.8 MV A at 46
kV. This line, as well as Haven Substation, is currently scheduled to be converted to 138 kV by
May 1 , 2007.
With the consideration of other proposed generation projects in the queue ahead of this project
there is adequate capacity available on either of these existing transmission lines to serve this
project. However, the study has identified limitations in the Borah West transmission system to
the west of this area. This study demonstrates that there is available transmission capacity
when considering other proposed generation projects ahead ofthis one in the queue. Because of
these limitations a Transmission System Impact Study will be required to detennine the
upgrades required to integrate this project into the Idaho Power system.
BEFORE THE IDAHO PUBLIC UTiliTIES
COMMISSION
CASE NO. IPC-O7-
IDAHO POWER COMPANY
ATTACHMENT 3
GENERATOR INTERCONNECTION
FEASIBILITY STUDY
for integration of the proposed
MILNER DAM WIND PARK PROJECT
III
TWIN FALLS COUNTY, IDAHO
to the
IDAHO POWER COMPANY ELECTRICAL SYSTEM
for
EXERGY DEVELOPMENT GROUP, LLC
the
INTERCONNECTION CUSTOMER
FINAL REPORT
January 3, 2007
1.0 Introduction
Exergy Development Group, LLC has contracted with Idaho Power Company (IPC) to perfonn a
Generator Interconnection Feasibility Study for the integration of the proposed 19.92 MW
Milner Dam Wind Park Project (project #157). The location of the project is in Idaho Power
southern Idaho service territory in portions of sections 25, 26 and 35 ofT1 OS, R20E and section
30 ofT10S, R21E in Twin Falls County, Idaho. This location starts approximately 2 miles west
of Idaho Power s existing Milner substation.
This report documents the basis for and the results of this Feasibility Study for the Milner Dam
Wind Park. It describes the proposed project, the study cases used, the impact of associated
projects, and results of all work in the areas of concern.
Summary
The proposed project is a 19.92 MW wind fann consisting of twelve 1.5 MW GE wind turbines.
The proposed point of interconnection for the wind fann with the IPC system is on the east edge
of section 25 about 0.4 miles north of the intersection of Milner Road and 1300 W. (Cassia
County coordinates).
This area is served by Idaho Power s 138 kV transmission system. With the consideration of
other proposed generation projects in the queue ahead ofthis project there is adequate capacity
available on the existing system in the immediate area to serve this project. However, this study
has identified limitations in the Midpoint West transmission system to the west of this area. This
study demonstrates that there is available transmission capacity when considering other
proposed generation projects ahead ofthis one in the queue. Therefore, a System Impact Study
will be required to determine the transmission upgrades needed to serve this project.
The substation serving this area is the Milner (MLNR) Substation. Capacity at the substation
will need to be increased by adding a second transfonner into an existing bay and opening the
substation bus so that only the feeder with the wind park is on this transformer.
The distribution feeder serving this area is Milner 043 (MLNR-043). Upgrades to the feeder will
be necessary to serve this project. About 0.9 miles of existing conductor will need to be
upgraded and 1.5 miles of new line installed to the point of interconnection.
Since the wind park will be located along with Idaho Power customer loads, a generation
interconnection package will be required at the point of interconnection.
The estimated cost of all required upgrades to serve the full project is $1 987 000. Lead time is
about 72 weeks.
The existing feeder can accept up to 15.4 MV A of generation at the point of interconnection
before feeder and/or substation upgrades are required. The cost to do the necessary work is
about $481 000.
Scope of Interconnection Feasibility Study
The Interconnection Feasibility Study was done and prepared in accordance with Idaho Power
Company Standard Generator Interconnection Procedures, to provide a preliminary evaluation of
the feasibility of the interconnection of the proposed generating project to the Idaho Power
system. All other proposed Generation projects prior to this project in the Generator
Interconnect queue were considered in this study. A current list of these projects can be found
on the Idaho Power web site as follows:
Small Generator (~20 MW):
http://www.idahopower.com! aboutus/business/ generationInterconnect/ generati onInterconnect. Cfill
Large Generator (~O MW):
http://www .oatioasis. comli pco/index.html.
Description of Proposed Generating Project
The Milner Dam Wind Park proposes to connect to the Idaho Power distribution system for an
injection of 19.92 MW (maximum project output) using twelve General Electric 1.5 MW wind
turbines.
Description of Existing Transmission Facilities
This area is served by Idaho Power s 138 kV transmission system. There are several 138 kV
lines that connect to Milner substation, as well as 69 kV and 46 kV transmission lines that leave
the Milner substation and serve the surrounding area. With the consideration of other existing
and proposed generation projects in the queue ahead of this project there is adequate capacity
available on this particular part of the system to serve this project. However, the study has
identified limitations in the Midpoint West transmission system to the west of this area. This
study demonstrates that there is available transmission capacity when considering other
proposed generation projects ahead of this one in the queue. Because of these limitations
, ~
Transmission System Impact Study will be required to detennine the next upgrades required to
add this project. An existing study is attached as Appendix C. This study details the existing
system limitations and describes the improvements necessary to increase the capacity of this
system another 305 MW. However, this capacity is already committed to other proposed
generation projects currently ahead of this one in the queue. The proposed study will detennine
the additional work necessary to integrate this project into the Idaho Power system.
Description of Existing Substation Facilities
The substation serving this area is Idaho Power s Milner (MLNR) Substation, which is located at
about 5260 E. and Milner Road in Twin Falls County. The existing substation transfonner is a
138:34.5 kV transfonner rated for 28.0 MV A. With the consideration ofthe size ofthe proposed
project, as well as other existing and proposed generation projects in the queue ahead of this
BEFORE THE IDAHO PUBLIC UTiliTIES
COMMISSION
CASE NO. IPC-O7-
IDAHO POWER COMPANY
ATTACHMENT 4
GENERATOR INTERCONNECTION
FEASIBILITY STUDY
for integration of the proposed
NOTCH BUTTE WIND PARK PROJECT
JEROME AND/OR LINCOLN COUNTIES, IDAHO
to the
IDAHO POWER COMPANY ELECTRICAL SYSTEM
for
EXERGY DEVELOPMENT GROUP, LLC
the
INTERCONNECTION CUSTOMER
FINAL REPORT
January 3, 2007
1.0 Introduction
Exergy Development Group, LLC has contracted with Idaho Power Company (IPC) to perfonn a
Generator Interconnection Feasibility Study for the integration of his new 19.92 MW Notch
Butte Wind Park Project (project #158). The proposed location of the project is in Idaho Power
southern Idaho service territory in section 36 ofT6S , Rl6E and sections 30 32 ofT6S, R17E
of Lincoln County as well as sections 3 9 ofT7S, R17E of Jerome County. This location
starts approximately 1 mile north or west ofIdaho Power s existing Notch Butte substation.
This report documents the basis for and the results of this Feasibility Study for the Notch Butte
Wind Park. It describes the proposed project, the study cases used, the impact of associated
projects, and results of all work in the areas of concern.
Summary
The proposed project is a 19.92 MW wind park consisting of twelve 1.5 MW wind turbines.
This wind fann will interconnect with the IPC system at about 900 N. and 200 E. in Jerome
County, Idaho.
The transmission line serving this area is Idaho Power s Twin Falls - Hydra - Midpoint 138 kV
line. With the consideration of other proposed generation projects in the queue ahead of this
project there is adequate capacity available on this line to serve this project. However, this study
has identified limitations in the 138 kV transmission system to the west of this area. This study
demonstrates that there is available transmission capacity when considering the projects in the
generation queue. Therefore, a System Impact Study will be required to detennine the
transmission upgrades needed to serve this project.
The substation serving this area is Idaho Power s Notch Butte (NHBT) substation. With the
consideration of the size of the proposed project there is not adequate capacity in this substation
to serve this project. A second substation transfonner will be required.
The distribution feeder serving this area is the Notch Butte 011 (NHBT-Oll) 12.5 kV feeder.
With the consideration of the size of the proposed project there is not adequate capacity on this
feeder to serve this project. A new 34.5 kV feeder will be required to serve this project. About 4
miles of the existing feeder will be rebuilt as a double circuit line, with the top circuit being a
34.5 kV feeder for the wind park.
Since the wind park could be located along with other Idaho Power customers, a generation
interconnection package will be required at the point of interconnection.
The estimated cost of all required upgrades is $2 114 000. Lead time is about 72 weeks.
The existing feeder can accept up to 3.82 MV A of generation at the point of interconnection
before feeder reconductoring is required.
Scope of Interconnection Feasibility Study
The Interconnection Feasibility Study was done and prepared in accordance with Idaho Power
Company Standard Generator Interconnection Procedures, to provide a preliminary evaluation of
the feasibility of the interconnection of the proposed generating project to the Idaho Power
system. All other proposed Generation projects prior to this project in the Generator
Interconnect queue were considered in this study. A current list of these projects can be found
on the Idaho Power web site as follows:
Small Generator (~20 MW):
hap: / /www . idahopower. com! a boutuslbusiness/ generationInterconnect/ generati onInterconnect. CfID
Large Generator (;;:20 MW):
http://www.oatioasis.com/it'co/index.htmi.
Because ofthe nature of these projects, this study was perfonned using the best-known
infonnation available as of this date.
Description of Proposed Generating Project
The Notch Butte Wind Park proposes to connect to the Idaho Power distribution system for an
injection of 19.92 MW (maximum project output) using twelve GE 1500 kW sle model wind
turbines.
Description of Existing Transmission Facilities
The transmission line serving this area is Idaho Power s Twin Falls - Hydra - Midpoint 138 kV
line. This line is a 22.85 mile 138 kV line with both 715 and 795 ACSR conductors, which has a
continuous thennal operating rating of 206.9 MV A. With the consideration of other proposed
generation projects in the queue ahead of this project there is adequate capacity available on this
particular line to serve this project. However, the study has identified limitations in the Midpoint
West transmission system to the west of this area. This study demonstrates that there is
available transmission capacity when considering other proposed generation projects ahead of
this one in the queue. Because of these limitations a Transmission System Impact Study will be
required to detennine the next upgrades required to add this project. An existing study is
attached as Appendix C. This study details the existing system limitations and describes the
improvements necessary to increase the capacity of this system another 305 MW. However, this
proposed capacity is already committed to other proposed generation projects currently ahead of
this one in the queue. The proposed study will detennine the additional work necessary to
integrate this project into the Idaho Power system.
Description of Existing Substation Facilities
The substation serving this area is Idaho Power s Notch Butte (NHBT) substation, which is
located at 700 N. and 400 E. in Jerome County. The existing substation transfonner is a
BEFORE THE IDAHO PUBLIC UTiliTIES
COMMISSION
CASE NO. IPC-O7-
IDAHO POWER COMPANY
ATTACHMENT 5
. ,
GENERATOR INTERCONNECTION
FEASIBILITY STUDY
for integration of the proposed
SALMON FALLS WIND PARK PROJECT
III
TWIN FALLS COUNTY, IDAHO
to the
IDAHO POWER COMPANY ELECTRICAL SYSTEM
for
EXERGY DEVELOPMENT GROUP, LLC
the
INTERCONNECTION CUSTOMER
FINAL REPORT
January 3, 2007
1.0 Introduction
Exergy Development Group, LLC has contracted with Idaho Power Company (IPC) to perform a
Generator Interconnection Feasibility Study for the integration of the new 19.92 MW Salmon
Falls Wind Park Project (project #159). There were two proposed locations for this project. The
area that was studied is in Idaho Power s southern Idaho service territory in sections
15 ofT8S , R13E and sections 7 and 18 ofT8S, R14E of Twin Falls County. This
location starts approximately 4 miles west of Idaho Power s existing Dale substation.
This report documents the basis for and the results of this Feasibility Study for the Salmon Falls
Wind Park. It describes the proposed project, the study cases used, the impact of associated
projects, and results of all work in the areas of concern.
Summary
The proposed project is a 19.92 MW wind park consisting of twelve to fourteen 1.5 MW wind
turbines. This wind farm will interconnect with the IPC system at about 5100 N. and 900 E. in
Twin Falls County, Idaho.
There are several transmission lines in this immediate area. Two transmission lines that could
feasibly serve this project are the 46 kV transmission system serving Idaho Power s existing
Thousand Springs Power Plant and the Upper Salmon "A" - Cliff 138 kV line. With the
consideration of other proposed generation projects in the queue ahead of this project there is
adequate capacity available on these lines to serve this project. However, the study has
identified limitations in the Midpoint West transmission system to the west of this area. This
study demonstrates that there is available transmission capacity when considering other
proposed generation projects ahead of this one in the queue. Because of these limitations
, ~
Transmission System Impact Study will be required to determine the upgrade required to
integrate this project into the Idaho Power system.
The substation serving the load in this area is Idaho Power s Dale (DALE) substation. With the
consideration of the size of the proposed project there is adequate capacity in this substation to
serve this project.
The distribution feeder serving this area is the Dale 43 (DALE-043) 34.5 kV feeder. With the
consideration of the size of the proposed project there is not adequate thermal capacity on this
feeder to serve this project. Preliminary studies also indicate that it would be difficult, ifnot
impossible, to maintain adequate voltage to the existing customers on the Dale feeders with the
addition of this project. Before this option is pursued further a Distribution System Impact Study
will be required.
Two alternatives were evaluated. The first is to build a dedicated substation for the wind park
and build a new 46 kV transmission line to an existing bay at the Thousand Springs Power Plant.
The estimated cost ofthis option is $2 300 000. Long lead items are estimated at 72 week
delivery from the time of order.
The second alternative is to build a dedicated substation and connect to the 138 kV Upper
Salmon - Cliffline. The estimated cost ofthis option is $2 650 000. Long lead items are
estimated at 72 week delivery trom the time of order.
Initial studies indicate that there is adequate load and short circuit interrupting capability on all
affected transmission breakers for either of these options.
Scope of Interconnection Feasibility Study
The Interconnection Feasibility Study was done and prepared in accordance with Idaho Power
Company Standard Generator Interconnection Procedures, to provide a preliminary evaluation of
the feasibility of the interconnection of the proposed generating project to the Idaho Power
system. All other proposed Generation projects prior to this project in the Generator
Interconnect queue were considered in this study. A current list of these projects can be found
on the Idaho Power web site as follows:
Small Generator (,20 MW):
http://www .idahopower. com! aboutus/businessl generationInterconnectl generati onInterconnectcfm
Large Generator (a!0 MW):
http://www.oatioasis.cornJi?co/index.htrnl
Because ofthe nature ofthese projects, this study was perfonned using the best-known
infonnation available as to date.
Description of Proposed Generating Project
The Salmon Falls Wind Park proposes to connect to the Idaho Power system for an injection of
19.92 MW (maximum project output) using twelve to fourteen GE 1500 kW SLE model wind
turbines.
Description of Existing Transmission Facilities
There are several transmission lines in this immediate area. The transmission line serving the
DALE substation is Idaho Power s King - American Falls 138 kV line. This line is a 138 kV line
with 715 ACSR "Starling" conductor, which has a continuous thennal operating rating of207.
MV A. Idaho Power s existing Thousand Springs Power Plant, which is located about 1 mile east
ofthe project, is on the 46 kV transmission system. This system has 397.5 ACSR "Ibis
conductor, rated for 47.8 MV A, going trom 1000 Springs Power to Hagennan substation and 2/0
Copper conductor, rated for 28.1 MV A, going trom 1000 Springs Power to Dale substation.
There is a 69 kV line east of the project that is limited in capacity by the substation transfonner
(see section 6.0 below). And finally the Upper Salmon "A" - Cliff 138 kV line runs thIOugh the
proposed project. This line has 795 ACSR "Tern" conductor rated for 219.5 MV A. With the