20141024Corrected Pages Helman Direct.pdf

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Chas. F. McDevitt
DeanJ. (oe) Millet
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Re:IPC-E-14-18; Sierta Club Testimony of Udi Helman
Dear Ms.Jewell:
After filing Mt. Helmao's Ditect Testimony yesterday I rliscoveted, due to ovetsight oo my parg oo
pages 9 and 10 that citations to vadous othet integration studies were omitted.
I am tansmitting the o'ig,.al and nine copies of corected pages 9 and 10 that include those
ciations. Kindly teplace the eadier pages with these. Fot the convenience of the Reportet a disc
q6at^ining tle cortected pages is also enclosed.
I hope this oversight will not cause inconvenience to the parties.
Very Truly Yours,
McDevitt & MilletLLPM
DJM/hh
C: Party of tecord, w/enclosute, by e-mail
Enclosutes
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results from the model in response to daa requests, and these results show some of the
operational changes needed for solar integration.
Eow do the solar integration costs in the Study compane to other solar integration
studies?
Given this methodological evaluatiorq the next issue is whether the resulting integration
costs are comparable to those from other studies, and if so, why. As noted in Phil DeVol's
testimony, the solar integration costs found in the study are comparable to those in other
studies that use similar simulation methods. There are a range of methodologies and some
charges are developed more transparently than others, but most appear to fall into a ftrnge
of $1 - $6lNIWh, depending on the quantrty of solar modeled, with higher costs for higher
quantities. Some ofthese integration cost forecasts are used for integrated resource
planning studies, while others are used to adjust avoided cost rates.
A PV integration study performed for NV Enerry calculated integration charges in the
range of $3/MWh forthe first 150 MW of PV to about $7l[\{Wh for 1,042 MW of PV, and
an additional $lilvfwh for PV curtaiLnent costs in the latter case. PacifiCorp in Utah has
proposed a solar integration charge deducted from its avoided cost rate for QF contracts of
$2.18iIvIWh for ftacking solar and $2.834,twh for fixed solar. APS has calculated a solar
integration cost of $2.08/I\dWh for 1,038 MW of solar, and $3.04/MWh for 1,669 MW of
solar. @lack & Veatch, Solar Photovoltaic (PV) Integration Cost Study, conducted for
APS, 2012.) BPA has calculated an integration charge of $0.21lkW-month for 23 MW of
solar. LADWP has calculated an integration of $7.64lMWh for up to 614 MW of solar.
(Cited in Los Angeles Deparhnent of Water and Power, 2013 Power Integrated Resource
Plan. December 16, 2013.) Tri-State has calculated a charge of $2.181N4Wh for 20 MW of
solar. (Tri-State Generation and Transmission Association, Inc. Integrated Resowce
Plon/Electric Resotrce P/ane, November20l0.) TEP has calculated a
Helnan, Di
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$5.20AdWh cost for the first 100 MW of solar PV, with an additional $1.10/l\dwh
for each additional 100 MW. (Tucson Elechic Power. 2014 Integrated Resource
Plan. April 1,2014.)
However, like the IPC study, these are all models attempting to estimate
future integration costs. We don't know whether these estimates are correct or
incorrect for the particular systems modeled until there is more operating
experience wittr wind and solar on these systems.
What power systems can we look to for examples of solar integration at high
penetrations?
There are a number of power systems around the world that have already
experianced high and increasing levels of solar generation, whether utility scale or
distributed. These ftmge from island systems, such as Hawaii, to large US states,
such as Califomia, and, of course, Germany. Of these, in the U.S., only Califonria
also has a transparent wholesale market operated by the California Independent
System Operator (CAISO), which gives more insight into how market prices and
costs are evolving with renewable integration.
How much renewable enerry is now on the California IS0 power system,
measured in the aggregate?
Under the33% RPS, the Califorria load-serving entities are required to achieve
33olo renewable energy, not including hydro, by 2020. Compliance could comp
earlier than2020 due to the potential for changes in financial incentives (e.g., the
investment tax credit), which is leading solar projects to come on-line earlier. Of
these load-serving entities, the Califonria investor-owned utilities are jtrisdictional
Hetnan, Di
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