20140701Youngblood Direct.pdf

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BEFORE THE IDAHO PUBLIC UTTLITIES COMMISSION
IN THE MATTER OF THE APPLICATION
OF IDAHO POI,IIER COMPANY 10
IMPLEMENT SOLAR INTEGRATION
RATES AND CHARGES.
CASE NO.IPC-E-14-18
IDAHO POWER COMPANY
DTRECT TESTIMONY
OF
MICHAEL .f. YOUNGBLOOD
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a.
A.
o.
A.
business address is 7221 West Idaho Street, Boise, fdaho.
O. By whom are you employed and in what capacity?
A. I am employed by Idaho Power Company ("Idaho
Power" or "Company") as the Manager of Regulatory Projects
in the Regulatory Affairs Department.
Please state your name and business address.
My name is Michael J. Youngblood and my
Please describe your educational background.
In May of L977, T received a Bachelor of
Science Degree in Mathematics and Computer Science from the
University of Idaho. From 7994 through L996, I was a
graduate student in the Executive MBA program of Colorado
State University. Over the years, I have attended numerous
industry conferences and trainj-ng sessions, including
Edison Electric Institute's "El-ectric Rates Advanced
Course. "
O.
Idaho Power.
A.
P1ease describe your work experience with
I began my employment with ldaho Power in
7977. During my career, I have worked in several
departments of the Company and subsidj-aries of IDACORP,
including Systems Development, Demand PIanning, Strategic
Planning, and IDACORP Solutions. Erom 1981 to 1988, I
worked as a Rate Analyst in the Rates and Planning
Department where I was responsible for the preparation of
YOUNGBLOOD, Dr 1
Idaho Power Company
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electric rate design studies and bill frequency analyses.
I was also responsible for the validation and analysis of
the load research data used for cost-of-service
allocations.
From 1988 through 1,991, T worked in Demand Planning
and was responsible for the load research and load
forecasting functions of the Compdny, incJ-uding sample
design, implementation, data retrieval, analysis, and
reporting. I was responsible for the preparation of the
fj-ve-year and twenty-year load forecasts used in revenue
projections and resource plansr dS wel-l- as the presentation
of these forecasts to the public and regulatory
commissions.
From 1997 through 1998, I worked in Strategic
Planning. As a Strategic Planning Associate, I coordinated
the complex efforts of acquirj-ng Prairie Power Cooperative,
the first acquisition of its kind for the Company in 40
years. From L996 to 1998, ds a part of a Strategic
Plannj-ng initiative, I helped develop and provide two-way
communication between customers and energy providers using
advanced computer technologies and tel-ecommunications.
Erom 1998 to 2000, I was a General Manager of
IDACORP Solutions, a subsidiary of IDACORP, reporting to
the Vice President of Marketing.
responsible for the direction
I was directly
YOUNGBLOOD, Dr 2
Idaho Power Company
1 and management of the Commercial and Industrial Business
2 Solutions division.
3 In 200L, T returned to the Regulatory Affairs
4 Department and worked on special projects related to
5 deregulation, the Company's Integrated Resource Plan
6 ("fRP"), and filings with both the Idaho Public Utilities
7 Commission (*IPUC" or "Commissj-on") and the Public Utility
I Commission of Oregon.
9 In 2008, I was promoted to the position of Manager
10 of Rate Design for Idaho Power. In that position I was
11 responsible for the management of the rate design
L2 strategies of the Company, as wel-I as the oversight of all
13 tarif f admi-nistration.
74 In January of 20L2, I became the Manager of
15 Regulatory Projects for Idaho Power, which is my current
76 position. In this position, I provide the regulatory
Ll support for many of the large individual projects and
18 issues currently facing the Company. Most recently that
L9 has included providing regulatory support for the inclusion
20 of the Langley Gulch power plant investment j-n rate base
27 and supporting the Company's efforts to address numerous
22 issues involving Qualifying Eacilities (*QF") as defined
23 under the Public Utility Regulatory Policies Act of 1978
24 (*PURPA"), including the Company's efforts in Case No. GNR-
25 E-11-03, the review of PURPA QF contract provisions.
YOUNGBLOOD, Dr 3
Idaho Power Company
l- Q. What is the purpose of your testimony in this
2 matter?
3 A. Idaho Power is requesting that the IPUC
4 authoxize the Company to implement solar integration rates
5 and charges consistent with its solar integration study
6 ("Study" or *2014 Study" or "Solar Study"). The 2074 So1ar
7 Study Report ("Study Report") is attached as Exhibit No. 1
8 to the testimony of Philip DeVol. Mr. DeVol's testimony
9 provides a summary of the Solar Study, a description of the
10 Technj-ca1 Review Committee and process utilized for the
11 Study, and the results of the 2074 Study. The purpose of
L2 my testj-mony is to provide the Commission wj-th the
l-3 Company's request to implement sol-ar integration rates and
74 charges based upon the costs identified by the Solar Study.
15 O. Based on the resul-ts of the 20L4 Study, what
16 is the cost of integrating solar generation on Idaho
t7 Power's electrical system?
18 A. As presented in Mr. DeVol-'s testi-mony, the
t9 Solar Study analyzed four sofar build-out scenarios at
20 install-ed capacities of: 100 megawatts ("MW"), 300 MW, 500
2L MW, and 700 MW. The results of the Solar Study show the
22 integration costs indicated in the following tables:
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YOUNGBLOOD, Dr 4
Idaho Power Company
Average Integration Cost per t'fi{h
(20L4 cost and dollars)
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Increnental. Integration Cost per MtNh
(2OL4 cost and dollars)
The costs identified by the Solar Study reflect the
costs to integrate sol-ar generation for the calendar year
20L4. The costs are reported in 20L4 dollars and were
rounded to the nearest ten (10) cents. They are not
averaged or Ievelized over the life of the solar project or
plant.
O. What is the dlfference between the Average
Integration Cost and the Incremental Integration Cost
described in the 2014 Study?
A. The Average Integration Costr ds shown above,
reports an average cost per megawatt-hour ("MWh") for each
of the four discrete solar buil-d-out scenarios modeled in
the Study. In other words, the Average Integration Cost
refl-ects the average cost per MWh to integrate one block of
sol-ar generation, independentJ-y, for each penetration level-
of solar generation: 0-100 MW; 0-300 MW; 0-500 MW; and 0-
700 MW. Conversely, the Incremental Integration Cost
indicates the cost of i-ntegrating solar generation as it
YOUNGBLOOD, DI 5
Idaho Power Company
Buil-d-out Scenarios 0-100 MW 0-300 MW 0-500 MW 0-700 MW
Integration Cost s0.40 $1.20 $1. B0 $2.s0
Penetration Level-0-100 MW 100-300 MW 300-500 MW 500-700 MW
Integration Cost s0.40 $1. s0 $2.80 $4.40
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would be assigned across the four blocks of solar
generation penetration levels, in 200 MW increments.
O. Please provlde an example to further explain
the distinction between Average fntegration Cost and
Incremental- Integration Cost.
A.Certainly. According to the 2014 Study, the
Average Integration Cost for al-l solar generation from 0-
700 MW is $2.50 per MWh. That means that if the total cost
of integrating 700 MW of solar were to be spread equally to
all 700 MW of solar generation, the cost of integration
would be $2.50 for each MWh generated. However, if that
same cost of integrating 700 MW of solar were to be broken
up into 100 and 200 MW increments, the Incremental
Integration Cost for the first 100 MW of sol-ar generation
would be only $0.40 per MWh. The incremental cost of
integration for the next 200 MW of sofar generatj-on (from
100 MW to 300 MW), assuming that the first 100 MW of solar
generation remains at $0.40 per MWh, woul-d be $1.50 per
MWh. For the next 200 MW (300 MW to 500 MW), again
assuming that the cost per MWh for the each of the first
two blocks of integration remaj-ned unchanged, would be a
cost of $2.80 per MWh. The last 200 MW (500 MW to 700 MW)
of sol-ar generation would incur a cost of $4.40 per MV{h.
In aggregate, the total cost of integrating solar
identified by ej-ther method, the Average Integration Cost
YOUNGBLOOD, DI 6
Idaho Power Company
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or the Incremental lntegration Cost, is the same.
EssentiaIIy, the cost of solar integration increases as the
penetration l-evels of solar increase on the system. The
Study identified the discrete cost to integrate solar
generation at four discrete penetration leveIs. However,
if costs are assigned on an incremental basis, then costs
are more closely assigned with the cause of those costs,
and thus the initial generation is assigned a lower cost
than the later generation that shows up when it is more
costly to integrate.
0.How does the Company propose to implement
sol-ar integration cost recovery?
A.fdaho Power proposes that a solar integration
charge be established to col-Iect the incremental- cost of
integration at each 100 MW of solar generation penetration.
Because there are not currently any solar projects paying
any integratj-on charge on Idaho Power's system, the sol-ar
integration charge simply starts at zero and j-ncreases
consistent with the costs of integration identified in the
Sol-ar Study, at every 100 MW of solar nameplate capacity
penetration level. The proposed solar integration charges
are rounded to the nearest penny and are illustrated in the
chart on the next page:
YOUNGBLOOD, Dr 7
Idaho Power Company
Ss.oo
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.E ss.oo
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E So.so
s-
Proposed lncremental Solar lntegration Charge
100 200 300 400 s00
Nameplate Penetration Level of Solar Capacity (MW)
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O. How does the Company propose that the Solar
Incremental Integration Charge be implemented for solar
generation?
A. Similar to what the Company submitted and will
request for the cost recovery of wind integration costs,
ldaho Power recommends that the Commission all-ocate costs
on a per MWh basis for incremental l-evel-s of solar
penetration, and not on a percentage of avoided cost rate
basis, like what was done for the initial- wind integration
charge. Idaho Power al-so proposes that both wind and solar
integration charges are set forth in a tariff schedule,
specifically established for intermittent generation
integration charges.
YOUNGBLOOD, Dr I
Idaho Power Company
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O. Have you provided an example of what an
integration tariff might look like?
A.Yes. Exhibit No. 2 to my testimony is a draft
Schedul-e 87, Variable Generation Integration Charges, that
I have prepared. The integration charges from Schedule 87
woul-d be deducted from the avoided cost rates established
for and set out in a PURPA contract.
O. Can you descrj-be the proposed Schedule 87,
Variable Generation Integration Charges, you provide in
Exhibit No. 2?
A.Yes. Schedule 87 is a draft of a new tariff
which is intended to provide the j-ncremental i-ntegrati-on
charges to be assessed to QFs whose generation resource is
variable and intermittent in nature, like wind or so1ar.
Schedule 87 would provide the wind and sol-ar integration
charges consistent with the most recent Commission-approved
integration study applicable to both wind and sol-ar
generation. The draft of Schedule 87 submitted as Exhibit
No. 2 contains onJ-y the proposed incremental integration
charges for solar generation based upon the 2074 Study, and
contains a placeholder for the inclusion of the appropriate
wind integration charges, once they are determined by the
Commission. The charges set forth in Schedule 87 are the
amounts to be deducted from avoided cost rates each year,
beginnj-ng in the year the project comes online, based on
YOUNGBLOOD, Dr 9
Idaho Power Company
1 the nameplate capacity of installed sol-ar generation at the
2 scheduled operation date of the proposed project. Being
3 tariff-based would a11ow integration costs to be updated
4 for new contracts as additional- solar generation is added
5 to the system, or whenever a new solar integration study is
6 completed and identifies a change in integration costs.
7 Having the costs set forth in Schedule 87 provides
8 transparency for the developers as to what the appropriate
9 integration charges wou1d be based upon the scheduled
10 operation date of the proposed project.
11 O. Can you describe the format in which the
72 integration charges are set out in Schedule 87?
13 A. Yes. Idaho Power has formatted the
14 integration charges to appear in the same format as that
15 used by the Commission to post the published avoided cost
1,6 rates. Each penetration level- (each 100 MW increment) has
71 its own table clearly identified and set forth in Schedul-e
18 81, and discloses both the levelized integration charge, ds
L9 well as the non-l-evelized stream of integratj-on charge
20 amounts listed by year. Just like published avoided cost
2L rates, the schedul-ed operatj-on date for the proposed
22 generation project is used as the starting point in the
23 table, and each yearly amount through the term of the
24 proposed contract is set out accordingly.
25 O. Does this conclude your testimony?
26 A. Yes it does.
YOUNGBLOOD, Dr 10
Idaho Power Company
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ATTESTATION OF TESTIMONY
STATE OE
County of
rDAHO )) ss.
Ada )
I, Michael J. Youngblood, havi-ng been duly sworn to
testify truthfully, and based upon my personal knowledqe,
state the following:
f am employed by Idaho Power Company as the Manager
of Regulatory Projects in the Regulatory Affairs Department
and am competent to be a witness in this proceeding.
I declare under penalty of perjury of the laws of
the state of Idaho that the foregoing pre-filed testimony
and exhibit are true and correct to the best of my
information and bel-ief .
DATED this l"t day of July 2014.
SUBSCRIBED AND S
July 20L4.
0bw
Idaho
exp]-res:
YOUNGBLOOD, Dr 11
Idaho Power Company
before
Nolary Pu
Residing ati
My commission
BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
GASE NO. IPC-E-14-19
IDAHO POWER GOMPANY
YOUNGBLOOD, DI
TESTIMONY
EXHIBIT NO.2
ldaho Power Company
I P t.l C No 29 Tariff No 101 OrioinalSheet No. 87-1
SCHEDULE 87
INTERMI]TENT GENERATION I NTEGRATION 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. Yean
I nte ntion al ly Left Bl a n k
PART 2 - SOLAR INTEGRATION CHARGES
The following tables are applicable to all QF solar generation contracts that come online after
August 1,2014:
Exhibit No. 2
Case No. IPC-E-14-18
M. Youngblood, IPC
Page 1 of8
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 OriqinalSheet No. 87-2
SCHEDULE 87
INTERMITTENT GENERATION I NTEGMTION CHARGES
(Continued)
SOLAR INTEGRATION CHARGES (Continued)
0 - 100 MW Solar Capacity Penetration Level
LEVELIZED
ON-LINE YEAR
20 YEAR
CONTRACT
TERM
LEVELIZED
RATES
2014
2015
2016
2017
2018
2019
0.54
0.s6
0.58
0.59
0.61
0.63
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
0.43
0.44
0.46
0.47
0.48
0.50
0.51
0.53
0.54
0.56
0.58
0.60
0.61
0.63
0.65
0.67
0.69
0.71
0.73
0.75
0.78
0.80
0.82
0.85
0.87
0.90
Exhibit No. 2
Case No. IPC-E-14-18
M. Youngblood, IPC
Page 2 of 8
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 OrioinalSheet No. 87-3
SCHEDULE 87
I NTERMITTENT GENERATION I NTEGRATION CHARGES
(Continued)
SOLAR INTEGRATION CHARGES (Continued)
101 - 200 MW Solar Capacity Penetration Level
LEVELIZED
ON-LINE YEAR
20 YEAR
CONTRACT
TERM
LEVELIZED
RATES
2014
2015
2016
2017
2018
2019
1.49
1.53
1.58
1.63
1.68
1.73
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
1.18
1.22
1.25
1.29
1.33
1.37
1.41
1.45
1.50
1.54
1.59
1.63
1.68
1.73
1.79
1.84
1.89
1.95
2.01
2.07
2.13
2.20
2.26
2.33
2.40
2.47
Exhibit No. 2
Case No.IPC-E-14-18
M. Youngblood, IPC
Page 3 of 8
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 OriqinalSheet No. 87-4
SCHEDULE 87
I NTERMITTENT GENERATION I NTEGRATION CHARGES
(Continued)
SOLAR I NTEGRATION CHARGES (Continued)
201 - 300 MW Solar Gapacity Penetration Level
LEVELIZED
ON-LINE YEAR
20 YEAR
CONTRACT
TERM
LEVELIZED
RATES
2014
2015
2016
2017
2018
2019
2.32
2.39
2.46
2.54
2.61
2.69
NON.LEVELIZED
CONTRACT
YEAR
NON-
LEVELIZED
RATES
20't4
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
1.U
1.89
1.95
2.01
2.07
2.13
2.20
2.26
2.33
2.40
2.47
2.55
2.62
2.70
2.78
2.87
2.95
3.04
3.13
3.23
3.32
3.42
3.52
3.63
3.74
3.85
Exhibit No. 2
Case No. IPC-E-14-18
M. Youngblood, IPC
Page 4 of 8
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
LP.U.C. No. 29. Tariff No. 101 OrioinalSheet No. 87-5
SCHEDULE 87
I NTERMITTENT GENERATION I NTEGRATION CHARGES
(Continued)
SOLAR INTEGRATION CHARGES (Continued)
301 - /m0 MW Solar Capacity Penetration Level
LEVELIZED
ON-LINE YEAR
20 YEAR
CONTRACT
TERM
LEVELIZED
RATES
20'14
2015
2016
2017
2018
2019
3.12
3.22
3.32
3.41
3.52
3.62
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
2.48
2.55
2.63
2.71
2.79
2.87
2.96
3.05
3.14
3.23
3.33
3.43
3.53
3.64
3.75
3.86
3.97
4.09
4.22
4.34
4.47
4.61
4.75
4.89
5.03
5.19
Exhibit No. 2
Case No. IPC-E-14-18
M. Youngblood, IPC
Page 5 of 8
IDAHO
lssued per Order No.
Effective -
lssued by IDAHO POWER COMPANY
Gregory W. Said, Vice President, Regulatory Affairc
1221West ldaho Street, Boise, ldaho
ldaho Power Company
|.P.U.C. No. 29. Tariff No. 101 OriqinalSheet No. 87€
SCHEDULE 87
INTERMITTENT GENEMTION I NTEGMTION CHARGES
(Continued)
SOLAR I NTEGRATION CHARGES (Continued)
401 - 500 MW Solar Capacity Penetration Level
LEVELIZED
ON-LINE YEAR
20 YEAR
CONTRACT
TERM
LEVELIZED
RATES
2014
2015
2016
2017
2018
2019
3.94
4.06
4.18
4.31
4.44
4.57
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
3.12
3.22
3.31
3.41
3.52
3.62
3.73
3.84
3.96
4.08
4.20
4.32
4.45
4.59
4.72
4.87
5.01
5.16
5.32
5.48
5.64
5.81
5.98
6.16
6.35
6.54
Exhibit No. 2
Case No. IPC-E-14-18
M. Youngblood, IPG
Page 6 of 8
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
l.P.U.C. No. 29. Tariff No. 101 OriqinalSheet No. 87-7
SCHEDULE 87
INTERMITTENT GENERATION INTEGMTION CHARGES
(Continued)
SOLAR INTEGRATION CHARGES (Continued)
501 - 600 MW Solar Capacity Penetration Level
LEVELIZED
ON-LINE YEAR
20 YEAR
CONTRACT
TERM
LEVELIZED
RATES
2014
2015
2016
20'17
2018
2019
4.76
4.91
5.05
5.2',1
5.36
5.52
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
3.78
3.89
4.01
4.13
4.25
4.38
4.51
4.64
4.78
4.93
5.07
5.23
5.38
5.55
5.71
5.88
6.06
6.24
6.43
6.62
6.82
7.02
7.24
7.45
7.68
7.91
Exhibit No. 2
Case No. IPC-E-14-18
M. Youngblood, IPC
Page 7 of 8
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
|.P.U.C. No. 29. Tariff No. 101 OriqinalSheet No. 87-8
SCHEDULE 87
INTERMITTENT GENERATION INTEGRATION CHARGES
(Continued)
SOLAR INTEGMTION CHARGES (Continued)
601 - 700 MW Solar Gapacity Penetration Level
LEVELIZED
ON-LINE YEAR
20 YEAR
CONTRACT
TERM
LEVELIZED
RATES
2014
20'15
2016
2017
2018
2019
5.54
5.71
5.88
6.06
6.24
6.43
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
4.39
4.53
4.66
4.80
4.95
5.09
5.25
5.40
5.57
5.73
5.91
6.08
6.26
6.45
6.65
6.85
7.05
7.26
7.48
7.70
7.94
8.17
8.42
8.67
8.93
9.20
Exhibit No. 2
Case No. IPC-E-14-18
M. Youngblood, IPC
Page 8 of 8
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