20140722Reply Comments.pdf

DONOVAN E. WALKER
Lead Counsel
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An IDACORP Company
July 22,2014
VIA HAND DELIVERY
Jean D. Jewell, Secretary
ldaho Public Utilities Commission
472 West Washington Street
Boise, ldaho 83702
Re: Case No. IPC-E-13-22
Update to Wind lntegration Rates and Charges - Reply Comments of ldaho
Power Company
Dear Ms. Jewell:
Enclosed for filing in the above matter are an original and seven (7) copies of the
Reply Comments of ldaho Power Company.
Very truly yours,
/')M
Donovan E. Walker
DEW:csb
Enclosures
122 1 W. ldaho St. (83702)
P.O. Box 70
Boise, lD 83707
DONOVAN E. WALKER (lSB No. 5921)
JULIA A. HILTON (lSB No. 7740)
ldaho Power Company
1221West ldaho Street (83702)
P.O. Box 70
Boise, Idaho 83707
Telephone: [phone]
Facsimile: [phone]
[e-mail]
ih i lton@ ida hopower. com
Attorneys for ldaho Power Company
IN THE MATTER OF IDAHO POWER
COMPANY'S APPLICATION TO UPDATE
ITS WIND INTEGRATION MTES AND
CHARGES.
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BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
CASE NO. tPC-E-13-22
REPLY COMMENTS OF
IDAHO POWER COMPANY
ldaho Power Company ("ldaho Powed' or "Company") respectfully submits the
following Reply Comments in response to the comments filed by the Idaho Public
Utilities Commission ("Commission") Staff ("Staff'), the American Wind Energy
Association ("AWEA"), and Renewable Northwest ("RNW") on July 2,2014. !n these
Reply Comments ldaho Power will address objections raised by AWEA and RNW,
correct statements from Idaho Power's initial Application relevant to Staffs
recommendation, and present Idaho Power's recommendation to implement wind
integration charges on an hourly incremental cost basis for every 100 megawatts
('MW") of penetration through an intermittent generation integration charge tariff.
REPLY COMMENTS OF IDAHO POWER COMPANY- 1
!. INTRODUCTION
On November 29,2013, ldaho Power filed its Application with the Commission
requesting authorization for ldaho Power to update its wind integration rates and
charges consistent with its 2013 Wind Integration Study Report ("2013 Study"). The
following parties intervened in the case: ldaho Winds LLC ("ldaho Winds"); Snake River
Alliance ("SRA"); Cold Springs Windfarm, LLC ("Cold Springs"); Desert Meadow
Windfarm, LLC ("Desert Meadow"); Hammett Hill Windfarm, LLC ("Hammett Hill");
Mainline Windfarm, LLC ("Mainline"); Ryegrass Windfarm, LLC ("Ryegrass"); Two
Ponds Windfarm, LLC ("Two Ponds"); Cassia Wind Farm LLC ("Cassia"); Hot Springs
Windfarm, LLC ("Hot Springs"); Bennett Creek Windfarm, LLC ("Bennett Creek");
Cassia Gulch Wind Park LLC ("Cassia Gulch"); Tuana Springs Energy, LLC ("Tuana");
High Mesa Energy, LLC ("High Mesa"); Renewable Northwest Project, which has since
changed its name to Renewable Northwest ; AWEA; ldaho Wind Partners l, LLC ("ldaho
Wind Partners"); Meadow Creek Project Company LLC ("Meadow Creek"); and
Rockland Wind Farm, LLC ("Rockland"). The Commission granted intervention to each
of the above parties.
On January 31 , 2014, Cold Springs, Desert Meadow, Hammett Hill, Mainline,
Ryegrass, Two Ponds, Cassia, Hot Springs, Bennett Creek, Cassia Gulch, Tuana, and
High Mesa collectively filed a Motion to Dismiss ("Cold Springs Motion to Dismiss"). On
February 7, 2014, AWEA and RNW filed comments in support of the Cold Springs
Motion to Dismiss; Meadow Creek, Rockland, and ldaho Wind Partners filed to join in
the Cold Springs Motion to Dismiss with additional comments; and ldaho Winds filed a
separate Motion to Dismiss. On February 21,2014,1daho Power filed an Answer to the
various motions to dismiss, joinders, and comments.
REPLY COMMENTS OF IDAHO POWER COMPANY- 2
On April 30,2014, in Order No. 33030, the Commission denied the Cold Springs
Motion to Dismiss and all motions to partially and/or fully dismiss the matter. ln Order
No. 33030, the Commission clarified that any "Commission approved modifications to
Idaho Power's wind integration rate and charges will only apply prospectively - to new
contracts as they are entered into by the parties and submitted to the Commission for
approval." Order No. 33030, p. 8. The Commission stated that parties had 14 days to
withdraw as intervenors if any party believed it no longer had a direct and substantial
interest in the proceeding. Rockland, Meadow Creek, ldaho Wind Partners, and SRA
withdrew from the case; an Amended Notice of Parties was issued on May 20,2014.
The remaining parties agreed that modified procedure could effectively process
the remainder of the case and set a procedural schedule that included a comment
deadline, settlement conference, and reply comment deadline. On July 2,2014, Staff
filed Comments and AWEA and RNW jointly filed Comments on the Company's
Application. ldaho Power submits these Reply Comments in response.
On July 9, 2014, the parties met to discuss settlement of the case. The parties
were unable to settle the case and desired additional time for discovery and comment
due to those discussions. On July 15, 2014, in Order No. 33075, the Commission
granted the parties' request for an additional procedural schedule, including deadlines
for additional discovery, supplementary comments, and supplementary reply comments.
II. REPLY COMMENTS
A. Staff Comments and Recommendations.
ldaho Power appreciates Staffs analysis and recommendations and agrees, in
particular, with Staffs recommendations: (1) to accept the results of the Company's
2013 Wind lntegration Study; (2) to recover the full incremental cost of integration from
REPLY COMMENTS OF IDAHO POWER COMPANY- 3
new wind projects; and (3) to implement integration charges as a dollar per megawatt-
hour ("MWh") charge rather than as a percentage of avoided cost rates. However,
Staff's recommendation with regard to the three tiers that were set forth in ldaho
Power's Application as "Method 1" is based upon an incorrect breakout of the tier levels
that ldaho Power erroneously reported in its Application. The Company's testimony
correctly set forth the tier and cost information; however, it was summarized erroneously
in the Application. ldaho Power, with these Reply Comments, will correct the
erroneously reported tier levels below. Additionally, given the Commission's decision
that existing qualifying facility ("QF") wind contracts will not be affected by any new
integration charges that may come about as part of this case, ldaho Power now has a
specific recommendation for implementation of wind integration charges-
implementation of the incremental wind integration cost quantified at 100 MW
increments-that the Company proposes below. Also relevant to Staff's initial
comments is a required clarification by the Company as to how the proposed
intermittent generation integration charge tariff would be structured and how it would
work. The Company clarifies its proposal regarding use of an integration tariff below.
The new procedural schedule approved by the Commission on July 15,2014, will allow
the parties to review ldaho Powefs proposed implementation of wind integration
charges, conduct discovery, if necessary, and submit supplemental comments thereto.
Order No. 33075.
1. Gorrection to Tier Levels and Costs in the Application.
Pages 5 and 6 of the Application include tables and charts which were intended
to be a summary of the 2013 Study results included in Mr. DeVol's testimony. Mr.
DeVol's testimony correctly sets forth the costs and the associated MW levels; however,
REPLY COMMENTS OF IDAHO POWER COMPANY.4
in drafting the Application, ldaho Power erroneously included incorrect MW levels on
page 6, paragraph 10. The dollar amounts are correct, it is only the associated MW
levels and tiers that are incorrect. The Application incorrectly indicates three tiers as:
800 MW to 999 MW; 1,000 MW to 1,199 MW; and 1,200 MW and above. From Mr.
DeVo!'s testimony, page 21, lines 9-22, the correct tier levels are: 678 MW to 800 MW;
801 MW to 1,000 MW; and 1,001 MW to 1,200 MW.
Additionally, the labeling that the Company attached to the chart on page 5 of the
Application does not correctly communicate the difference between the costs identified
by the build-out scenarios from the 2013 Study and the incremental integration cost at
different penetration levels. Lastly, the 2013 Wind lntegration Study utilized a 2017 test
year, and reports all numbers in 2017 dollars. Once again, the dollar amounts are
correct, only the MW levels and labels have been clarified. ldaho Power provides the
following tables, meant as replacement tables for those that appear on pages 5 and 6 of
the Application.
Clarified and replacement table for paragraph 7, page 5 of the Application:
Average lntegration Cost Per MWh
Build-out Scenarios 0-800 MW 0-1.000 MW 0-1,200 MW
lntegration Cost
QO17 dollars)
$6.83 $10.22 $14.22
lntegration Cost
eO14 dollars)
$6.25 $9.35 $13.01
lncremental lntegration Cost Per MWh
Penetration Level 678-800 MW 801-1 ,000 MW 1 .001-1 .200 MW
lntegration Cost
QO17 dollars)
$8.67 $24.00 $34.70
lntegration Cost
eO14 dollars)
$7.93 $21.96 $31.76
REPLY COMMENTS OF IDAHO POWER COMPANY- 5
Corrected and replacement table for paragraph 10, page 6 of the Application (still
in 2017 dollars):
Amount of Wind Online lntesration Charse
678 MW to 800 MW
801 MW to 1,000 MW
1,001 MW to 1,200 MW
The numbers reported above, and reported by the 2013 Study, are 2017
calendar year costs. These numbers are not levelized or averaged numbers. The full
stream of yearly cost numbers is set forth in Schedule 87 as described below, and set
forth in Attachment t hereto.
2. Proposed lntermittent Generation lntegration Gharge Tariff.
Because the initial Application contained multiple options/proposals for the
implementation of updated wind integration costs, the Company's proposal to
implement an intermittent generation integration charge tariff is somewhat different
today, given the Commission's determination that existing integration charges wil! not
be changed. ldaho Power does not propose that integration charges, once contained in
a Commission-approved Public Utility Regulatory Policies Act of 1978 ('PURPA')
energy sales agreement, be changed during the term of the contract. ldaho Power
proposes a new tariff, Schedule 87, lntermittent Generation Integration Charges. This is
the same Schedule 87 and proposal that the Company recently submitted for the
implementation of solar integration costs in Case No. IPC-E-14-18. The tariff does not
provide for modifying or changing the integration cost that is contained in a
Commission-approved contract. The tariff, and any change to the integration charge in
the future, would only apply to new contracts and obligations entered into subsequent to
its approval by the Commission.
REPLY COMMENTS OF IDAHO POWER COMPANY- 6
Tier 1
Tier 2
Tier 3
$8.67/MWh
$24.00/MWh
$34.70/MWh
Schedule 87 is meant to provide the wind and solar integration charges
consistent with the most recent Commission-approved integration study applicable to
both wind and solar generation, respectively. The Company has provided a draft of
Schedule 87, submitted as Attachment t hereto and incorporated herein by this
reference, which contains only the proposed incremental integration charges for wind
generation based upon the 2013 Study. lt also contains a placeholder for the inclusion
of the appropriate solar integration charges, once they are determined by the
Commission. (The Company submitted the same draft Schedule 87 as Exhibit No. 2 in
Case No. IPC-E-14-18 that contains the proposed incremental integration charges for
solar generation, and a placeholder for the inclusion of an appropriate wind integration
charge.) The charges set forth in Schedule 87 are the amounts to be deducted from
avoided cost rates each year, beginning in the year the project comes on-line, based on
the nameplate capacity of installed wind generation at the scheduled operation date of
the proposed new project. The integration charges set forth in Schedule 87 are
formatted to appear in the same format as that used by the Commission to post the
published avoided cost rates. Each penetration level (for each 100 MW increment of
wind penetration) has its own table clearly identified and set forth in Schedule 87, and
discloses both the levelized integration charge as well as the non-levelized stream of
integration charge amounts listed by year. Just like published avoided cost rates, the
scheduled operation date for the proposed generation project is used as the starting
point in the table, and each yearly amount through the term of the proposed contract is
set out accordingly. These amounts would be included in the PURPA energy sales
agreement for a new project, and would remain as set forth in that agreement for the
entire term of the agreement.
REPLY COMMENTS OF IDAHO POWER COMPANY- 7
B. ldaho Power's Recommended lmplementation of Wind lnteqration Charqes.
The 2013 Study identified wind integration costs at 800 MW, 1 ,000 MW, and
1,200 MW. The incremental integration costs at 100 MW increments were determined
by first fitting a smooth curye to each of the studied penetration level costs identified in
the 2013 Study, from 0 MW to 1,200 MW. Attachment 2 shows the resulting curves
(one in 2017 dollars and the other in 2014 dollars) and their respective formulas. The
incremental integration costs at each of the 100 MW increment levels of penetration
were then determined by using the respective curve's formula to identify the associated
costs on the curve. The resulting 100 MW incremental integration costs are shown on
the graphs submitted herewith as Attachment 3, both in 2017 and 2014 dollars, and
incorporated herein by this reference.
ldaho Power's proposal to implement wind integration costs at 100 MW
increments is the same as its proposal to implement solar integration costs at 100 MW
increments. Similar to the explanation presented in the testimony of Mr. Youngblood in
the solar case, the 2013 Wind lntegration Study identified an average integration cost
for all wind generation from 0-1,200 MW of $14.22. That means that if the total cost of
integrating 1,200 MW of wind were to be spread equally to all 1,200 MW of wind
generation, the cost of integration would be $1 4.22for each MWh generated. However,
if that same cost of integrating 1,200 MW of wind were to be broken up into increments,
the incremental integration cost for the first increments would be much lower, while the
cost for the later increments increases. ln aggregate, the total cost of integrating wind
indentified by either method, the average integration cost or the incremental integration
cost, is the same. The cost of wind integration increases as the penetration level of
wind increases on the system. The 2013 Study identified the discrete cost to integrate
REPLY COMMENTS OF IDAHO POWER COMPANY. S
wind generation at three discrete penetration levels. However, if costs are assigned on
an incremental basis, then costs are more closely assigned with the cause of those
costs, and thus the initia! generation is assigned a lower cost than the later generation
that shows up when it is more costly to integrate.
ldaho Power proposed that a wind integration charge be established to collect
the incremental cost of integration at each 100 MW level of wind generation penetration.
Because ldaho Power currently has 678 MWI of wind currently operating on its system,
the updated wind integration charge starts at the 678 MW to 700 MW penetration level,
and increases consistently with the costs of integration identified in the 2013 Study, at
every 100 MW of wind nameplate capacity penetration level. This results in proposed
wind integration charges, in 2017 dollars, of: $13.10 for 678 MW to 700 MW; $t 7.00 for
701 MW to 800 MW; $2t.35 for801 MW to 900 MW; $20.t6 for 901 MW to 1,000 MW;
$31.41 for 1,001 to 1,100 MW; and $37.08 for 1,101 MW to 1,200 MW. These numbers
are shown on the graph submitted herewith as page 1 of Attachment 4, and
incorporated herein by this reference. Page 2 of Attachment 4 are the same numbers in
2014 dollars.
ldaho Power proposes that the incremental cost of wind integration, at 100 MW
increments, be implemented and set forth as proposed in Schedule 87, lntermittent
Generation lntegration Charges, as described above. Because the Company already
has 678 MW of wind generation on its system, the first wind integration costs identified
are those for the 601 MW to 700 MW of wind penetration.
'With the recent inclusion of 50 MW of wind generation from five fully executed PURPA energy
sales agreements in its Oregon jurisdiction, ldaho Power's total current wind generation penetration level
is 728 MW.
REPLY COMMENTS OF IDAHO POWER COMPANY- 9
C. AWEA and RNW Obiections.
AWEA and RNW (hereafter, 'AWEA') object to the validity of the costs identified
by the 2013 Study, and cite two primary objections to the 2013 Study methodology: (1 )
hour-ahead versus day-ahead wind forecast data and (2) netting the reserve
requirements for load and wind. AWEA characterizes the treatment of these issues as
ldaho Power taking a step backwards and abandoning utility "best practices" by
erroneously using day-ahead forecast data and not netting load and wind reserves
because these two items were addressed by using hour-ahead data and netting of
reserves in the 2007 Wind lntegration Study.
Alarmingly, it appears that the Company's use of best
practices in its wind integration methodology has actually
diminished over the past seven years, as many of the errors
in the 2013 Study were not made in Idaho Power's 2007
Wind lntegration Study . . . Most importantly, ldaho Power's
2013 Study does not incorporate the use of hour-ahead wind
forecasts and fails to net the reserve requirements of wind
and load; these methodological flaws are described in detail
in the following two sections.
AWEA/RNW Comments, p. 4.
ldaho Power did not abandon the use of "best practices" and its understanding of
wind integration and its associated costs has not "diminished" over the years since the
initial 2007 Study was conducted. ln fact, at the time of the 2007 Study, ldaho Power
had very little wind generation actually operating on its system (just under 20 MW with
only the Fossi! Gulch and Horseshoe Bend Wind projects on-line), compared to the 678
MW of wind generation that it successfully integrates onto its system today. lt is exactly
the experience that ldaho Power has gained over the past seven plus years of actual
operations of its system, reliably serving its customers in a least-cost manner as
required by its regulatory compact, that specifically informed the Company's conscious
REPLY COMMENTS OF IDAHO POWER COMPANY- ,IO
decisions to change to the day-ahead wind forecast and to not net the reserve
requirements of load and wind in its 2013 Study. AWEA admittedly advocated for
general policy considerations for integration studies on the whole, and from a national
perspective. However, it fails to take into account ldaho Powe/s own specific and real-
world operation of its system, the way that costs are incurred and recovered (or not),
and the way that the markets function that ldaho Power has access to and participates
in. The decisions about how to conduct a proper wind integration study is not a one-
size-fits-all, plug-and-play endeavor that is the same for ldaho Power as it is for another
utility that may reside inside of an RTO/ISO such as exists in other parts of the country.
ln addition, the fact that all but 101 MW of the 678 MW of wind on ldaho Powe/s
system is PURPA generation makes a significant difference because the Company
does not have the operational flexibility with PURPA generation that it may have (or
another utility may have) if its wind generation is non-PURPA. Because the PURPA
generation is a designated network resource to serve load on the Company's system,
and the Company must accept delivery whenever it is delivered by QF projects, the
decisions must be made about the designation/undesignation of ldaho Power's other
resources in order to keep the system balanced and reliably serving load. These
decisions incur costs. The integration studies attempt to quantify some of these costs.
ldaho Power, in the conduct of the initial 2OO7 Study, did choose to use hour-
ahead forecast data and to net the reserves of load and wind for many of the same
reasons that AWEA advocates: that it was held out as "standard" utility best practice in
the conduct of an integration study. With little operational experience at that time, the
decision to follow that mode! made sense for the circumstances at that time. However,
ldaho Power has gained a large amount of wind generation, and much more experience
REPLY COMMENTS OF IDAHO POWER COMPANY. 11
integrating that generation onto its system. Consequently when making those decisions
for the updated 2013 Study, Idaho Power chose to use day-ahead wind forecast data
and to not net load and wind reserves. This was done primarily because it is reflective
of actual operations where Idaho Power incurs costs on a day-ahead basis, based upon
the day-ahead forecast, as it must to prudently operate its system and reliably serve
load. Because of the non-liquidity in hour-ahead and realtime markets that exist in
ldaho Power's region and to which ldaho Power has access to, the Company is not able
to reliably recover these sunk day-ahead costs as it balances its system to real time.
AWEA's characterization of day-ahead system scheduling as "forecast" is not
accurate. Day-ahead scheduling for ldaho Power typically includes actual transactions
with third parties, and these transactions obligate the Company and incur costs to
provide or accept energy for the next day, and are not merely forecasts. Additionally,
day-ahead forecasts for load and day-ahead forecasts for wind are not the same thing
as AWEA implies; forecasting wind generation a day ahead is considerably more
difficult. AWEA/RNW correctly note in their Comments that wind energy forecast error
is greatly reduced as forecast lead time is reduced. AWEA/RNW Comments pp. 5-6. ln
fact, it is precisely the magnitude and nature of the day-ahead wind forecast error that
requires Idaho Power, as an entity having a mandate to reliably serve load, to set aside
capacity day ahead to allow response to wind forecast errors.
By comparison, system load is less difficult to forecast a day ahead, and day-
ahead load forecast errors are typically less problematic. The National Renewable
Energy Laboratory ("NREL") explains in a July 2012 conference paper on a comparison
between load and wind forecasting: "Load generally follows a familiar pattern, reaching
its peak during the day and into the evening, with a nighttime nadir." A Comparison of
REPLY COMMENTS OF IDAHO POWER COMPANY- 12
Wind Power and Load Forecasting Error Distributions, Bri-Mathias Hodge, Anthony
Florita, Kirsten Onruig, Debra Lew, Michael Milligan, National Renewable Energy
Laboratory, May 2012. NREL also importantly notes that significant day-ahead load
forecast errors are often auto correlated, reflecting a tendency for day-ahead load
forecast errors to persist in magnitude and direction throughout the day. Because of
this tendency, day-ahead load forecast errors are more readily addressed through the
hour-by-hour management in real time described by AWEfuRNW in their Comments.
Thus, the challenges in forecasting wind and load for day-ahead unit commitment
are considerably different, requiring the system to treat differently the possibility of
errors in forecasting these two elements of the load and resource balance. Moreover,
the different treatments necessary for load and wind make impractical the netting
advocated by AWEA/RNW in the analysis of errors for load and wind.
ilr. coNcLUStoN
ldaho Power agrees with Staff's recommendations, particularly Staff's
recommendations: (1) to accept the results of the Company's 2013 Wind lntegration
Study; (2) to recover the full incremental cost of integration from new wind projects; and
(3) to implement integration charges as a dollar per MWh charge rather than as a
percentage of avoided cost rates. ldaho Power respectfully proposes further that a wind
integration charge be implemented to recover the full incremental cost of integration at
100 MW increments, and that those charges be set forth in Schedule 87 for intermittent
generation integration charges. AWEA/RNW's objections to the study methodology
may be fair criticisms of studies in general and from a nationwide perspective, but they
are without merit as it pertains to the use of day-ahead forecast data and the netting of
reserves for ldaho Power because of the way costs are actually incurred in the
REPLY COMMENTS OF IDAHO POWER COMPANY- 13
operation of ldaho Power's system on a day-ahead basis, with a very limited ability to
recover them as the system balances into real time.
ldaho Power respectfully requests that the Commission approve the updated
wind integration costs as identified herein and set forth in the proposed Schedule 87.
DATED at Boise, ldaho, this 22nd day of July 2014.
n,7)tu1u/
DONOVAN E. WALKER
Attorney for ldaho Power Company
REPLY COMMENTS OF IDAHO POWER COMPANY- 14
CERTIFICATE OF SERVICE
! HEREBY CERTIFY that on the 22nd day of July 2014 I served a true and correct
copy of the REPLY COMMENTS OF IDAHO POWER COMPANY upon the following
named parties by the method indicated below, and addressed to the following:
Gommission Staff
Kristine A. Sasser
Deputy Attomey Genera!
ldaho Public Utilities Commission
472 West Washington (83702)
P.O. Box 83720
Boise, ldaho 83720-007 4
ldaho Winds LLC
Dean J. Miller
McDEVITT & MILLER LLP
420 West Bannock Street (83702)
P.O. Box 2564-83701
Boise, ldaho 83701
Rick Koebbe, President
ldaho Winds LLC
5420 West Wicher Road
Glenns Ferry, ldaho 83623
Bob Eggers, Legal Counsel
ldaho Winds, LLC
15850 Jess Ranch Road
Tracy, California 95377
Cold Springs Windfarm, LLC; Desert
Meadow Windfarm, LLG; Hammett Hill
Windfarm, LLC; Mainline Windfarm, LLC;
Ryegrass Windfarm, LLC; and Two Ponds
Windfarm, LLC
Peter J. Richardson
RICHARDSON ADAMS, PLLC
515 North 27th Street
Boise, ldaho 83702
Hand Delivered
U.S. Mail
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REPLY COMMENTS OF IDAHO POWER COMPANY- 15
Benjamin G. Huang, Manager
c/o Mountain Air Projects
6000 North Foxtail Way
Glenns Ferry, ldaho 83623
Gassia Wind Farm LLC; Hot Springs
Windfarm, LLC; Bennett Creek Windfarm,
LLC; Cassia Gulch Wind Park LLC; Tuana
Springs Energy, LLC; and High Mesa
Energy, LLC
Gregory M. Adams
RICHARDSON ADAMS, PLLC
515 North 27th Street
Boise, ldaho 83702
PaulAckerman
Assistant General Counsel
Exelon Business Services Corporation
100 Constellation Way
Baltimore, Maryland 21202
American Wind Energy Association and
Renewable Northwest Project
Teresa A. Hill
K&L GATES, LLP
One S.W. Columbia Street, Suite 1900
Portland, Oregon 97258
Dina M. Dubson
Renewable Northwest Project
421 SW 6th Avenue, Suite 1'125
Portland, Oregon 97204
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Bearry, -Legal Assistant
REPLY COMMENTS OF IDAHO POWER COMPANY- 16
BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
GASE NO. IPC-E-13-22
IDAHO POWER COMPANY
ATTACHMENT 1
ldaho Power Company
!.P.U.C. No. 29. Tariff No. 101 OriqinalSheet No. 87-1
SCHEDULE 87
INTERMITTENT GENERATION INTEGRATION CHARGES
APPLICABILITY
This schedule is applicable to all qualifying facility ('QF') generators interconnected to the
Company that have generation of an intermittent nature, such as wind and solar generation. The initial
charges within this schedule are to be assessed to intermittent generation based upon the total
nameplate capacity of a specific type of intermittent generation interconnected to Company's system.
PART 1 - WIND INTEGRATION CHARGES
The following tables are applicable to all QF wind generation contracts that come online after
Month Dav. Year
Continued on next page
IDAHO
lssued per Order No.
Effective -
lssued by IDAHO POWER COMPANY
Gregory W. Said, Vice President, Regulatory Affairs
1221West ldaho Street, Boise, ldaho
ldaho Power Company
!.P.U.C. No. 29. Tariff No. 101 Orioinal Sheet No. 87-2
SCHEDULE 87
INTERMITTENT GENERATION INTEGRATION CHARGES
(Continued)
WIND INTEGRATION CHARGES (Continued)
IDAHO lssued by IDAHO POWER COMPANY
lssued per Order No. Gregory W. Said, Vice President, Regulatory Affairs
Effective - 1221\Nest ldaho Street, Boise, ldaho
601 - 700 MW Wind Capacity Penetration Level
LEVELIZED
ON-LINE YEAR
20 YEAR
CONTRACT
TERM
LEVELIZED
RATES
2014
2015
2016
2017
2018
2019
15.13
15.58
16.05
16.53
17.03
17.54
NON.LEVELIZED
CONTRACT
YEAR
NON-
LEVELIZED
RATES
2014
2015
2016
2017
2018
2019
2020
2021
2022
2023
2024
2025
2026
2027
2028
2029
2030
2031
2032
2033
2034
2035
2036
2037
2038
2039
11.99
12.35
12.72
13.10
13.50
13.90
14.32
14.75
15.19
15.65
16.12
16.60
17.10
17.61
18.14
18.68
19.24
19.82
20.42
21.03
21.66
22.31
22.98
23.67
24.38
25.11
ldaho Power Company
|.P.U.C. No. 29. Tariff No. 101 OriqinalSheet No. 87-3
SCHEDULE 87
INTERMITTENT GENERATION INTEGRATION CHARGES
(Continued)
WIND INTEGRATION CHARGES (Continued)
701 - 800 MW Wind Capacity Penetration Level
LEVELIZED
ON-LINE YEAR
20 YEAR
CONTRACT
TERM
LEVELlZED
RATES
2014
2015
2016
2017
2018
2019
19.62
20.21
20.82
21.44
22.09
22.75
NON.LEVELIZED
CONTRACT
YEAR
NON-
LEVELIZED
RATES
2014
2015
2016
2017
2018
2019
2020
2021
2022
2023
2024
2025
2026
2027
2028
2029
2030
2031
2032
2033
2034
2035
2036
2037
2038
2039
15.55
16.02
16.50
17.00
17.51
18.03
18.57
19.13
19.70
20.29
20.90
21.53
22.18
22.84
23.53
24.23
24.96
25.71
26.48
27.27
28.09
28.93
29.80
30.70
31.62
32.57
IDAHO
lssued per Order No.
Effective -
lssued by IDAHO POWER COMPANY
Gregory W. Said, Vice President, Regulatory Affairs
1221 West ldaho Street, Boise, ldaho
ldaho Power Company
I.P.U.C. No. 29. Tariff No. 101 OriqinalSheet No. 874
SCHEDULE 87
INTERM ITTENT GENERATION I NTEGRATION CHARGES
(Continued)
WIND INTEGRATION CHARGES (Continued)
801 - 900 MW Wind Capacity Penetration Level
LEVELIZED
ON-LINE YEAR
20 YEAR
CONTRACT
TERM
LEVELIZED
RATES
2014
2015
2016
2017
2018
2019
24.65
25.39
26.16
26.94
27.75
28.58
NON.LEVELIZED
CONTRACT
YEAR
NON-
LEVELIZED
RATES
2014
2015
2016
2017
2018
2019
2024
2021
2022
2023
2024
2025
2026
2027
2028
2029
2030
2031
2032
2033
2034
2035
2036
2037
2038
2039
19.54
20.13
20.73
21.35
21.99
22.65
23.33
24.03
24.75
25.50
26.26
27.05
27.86
28.70
29.56
30.44
31.36
32.30
33.27
34.26
35.29
36.35
37.44
38.56
39.72
40.91
IDAHO
lssued per Order No.
Effective -
lssued by IDAHO POWER COMPANY
Gregory W. Said, Vice President, Regulatory Affairs
1221 West ldaho Street, Boise, ldaho
ldaho Power Company
I.P.U.C. No. 29. Tariff No. 101 Oriqlnal Sheet No. 87-5
SCHEDULE 87
INTERMITTENT GENERATION INTEGRATION CHARGES
(Continued)
WIND INTEGRATION CHARGES (Continued)
IDAHO lssued by IDAHO POWER COMPANY
lssued per Order No. Gregory W. Said, Vice President, Regulatory Affairs
Effective - 1221West ldaho Street, Boise, ldaho
901 - 1000 MW Wind Capacity Penetration Level
LEVELIZED
ON-LINE YEAR
20 YEAR
CONTRACT
TERM
LEVELIZED
RATES
2014
2015
2016
2017
2018
2019
30.21
31.11
32.04
33.01
34.00
35.02
NON.LEVEL'ZED
CONTRACT
YEAR
NON-
LEVELIZED
RATES
2014
2015
2016
2017
2018
2019
2024
2021
2022
2023
2024
2025
2026
2027
2028
2029
2030
2031
2032
2033
2034
2035
2036
2037
2038
2039
23.94
24.66
25.40
26.16
26.94
27.75
28.59
29.44
30.33
31.24
32.17
33.14
34.13
35.16
36.21
37.30
38.42
39.57
40.76
41.98
43.24
44.54
45.87
47.25
48.66
50.12
ldaho Power Company
|.P.U.C. No. 29. Tariff No. 101 OriqinalSheet No. 87-6
SCHEDULE 87
I NTERM ITTENT GENERATION INTEGRATION CHARGES
(Continued)
WIND INTEGRATION CHARGES (Continued)
1001 - 1100 MW Wind Capacity Penetration Level
LEVELIZED
ON-LINE YEAR
20 YEAR
CONTRACT
TERM
LEVEL!ZED
RATES
2014
2015
2016
2017
2018
2019
36.26
37.35
38.47
39.63
40.81
42.04
NON.LEVELIZED
CONTRACT
YEAR
NON-
LEVELIZED
RATES
2014
2015
2016
2017
2018
2019
2020
2021
2022
2023
2024
2025
2026
2027
2028
2029
2030
2031
2032
2033
2034
2035
2036
2037
2038
2039
28.74
29.60
30.49
31.41
32.35
33.32
34.32
35.35
36.41
37.50
38.63
39.78
40.98
42.21
43.47
44.78
46.12
47.51
48.93
50.40
51.91
53.47
55.07
56.72
58.43
60.18
IDAHO
lssued per Order No.
Effective -
lssued by IDAHO POWER COMPANY
Gregory W. Said, Vice President, Regulatory Affairs
1221West ldaho Street, Boise, ldaho
ldaho Power Company
|.P.U.C. No. 29. Tariff No. 101 Oriqinal Sheet No. 87-7
SCHEDULE 87
INTERMITTENT GENERATION INTEGRATION CHARGES
(Continued)
WIND INTEGRATION CHARGES (Continued)
1101 - 1200 MW Wind Gapacity Penetration Level
LEVELIZED
ON-LINE YEAR
20 YEAR
CONTRACT
TERM
LEVELIZED
RATES
2014
2015
2016
2017
2018
2019
42.81
44.10
45.42
46.78
48.19
49.63
NON.LEVELIZED
CONTRACT
YEAR
NON-
LEVELIZED
RATES
2014
2015
2016
2017
2018
2019
2020
2021
2022
2023
2024
2025
2026
2027
2028
2029
2030
2031
2032
2033
2034
2035
2036
2037
2038
2039
33.93
34.95
36.00
37.08
38.19
39.34
40.52
41.73
42.98
44.27
45.60
46.97
48.38
49.83
51.33
52.87
54.45
56.09
57.77
59.50
61.29
63.12
65.02
66.97
68.98
71.05
IDAHO
lssued per Order No.
Effective -
lssued by IDAHO POWER COMPANY
Gregory W. Said, Vice President, Regulatory Affairs
1221 West Idaho Street, Boise, ldaho
ldaho Power Company
|.P.U.C. No. 29. Tariff No. 101 OriqinalSheet No. 87-8
SCHEDULE 87
INTERMITTENT GENERATION INTEGRATION CHARGES
(Continued)
PART 2 - SOLAR INTEGRATION CHARGES
The following tables are applicable to all QF solar generation contracts that come online after Month.
Dav. Yean
I ntentionally Left Blank
IDAHO
lssued per Order No.
Effective -
lssued by IDAHO POWER COMPANY
Gregory W. Said, Vice President, Regulatory Affairs
1221West ldaho Street, Boise, ldaho
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IDAHO POWER COMPANY
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