20170623Angell Rebuttal .pdf

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An IDACORP Companv
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DONOVAN E. WALKER
Lead Counsel
[e-mail]
June 23,2017
VIA HAND DELIVERY
Diane M. Hanian, Secretary
Idaho Public Utilities Commission
472 West Washington Street
Boise, ldaho 83702
Case No. IPC-E-16-28
Certificate of Public Convenience and Necessity for Wood River Valley
ldaho Power Company's Rebuttal Testimony
Dear Ms. Hanian
Enclosed for filing in the above matter are an original and eight (8) copies each of
the Rebuttal Testimony of N. Vern Porter and the Rebuttal Testimony of David M. Angell.
One copy of each of the aforementioned testimonies has been designated as the
"Reporter's Copy." ln addition, a disk containing Word versions of the testimonies is
enclosed for the Reporter.
Very truly yours,
i:i ,tji; i': I 1/ L: [i 3Iffi*
gtddlQ"
Re
Donovan E. Walker
DEW:csb
Enclosures
1221 W. ldaho St. (83702)
P.O. Box 70
Boise, lD 83707
firC I IVED
tiil ,iti;i ?3 P*11 3: 50
BEFORE THE TDAHO PUBLIC UT]LITIES COMMTSSION
I Iil!;'!ti{\:11riitr ir)i:-Lii
IN THE MATTER OF THE APPLICATION
OE IDAHO POWER COMPANY EOR A
CERTIFICATE OF PUBLIC CONVENIENCE
AND NECESSITY FOR THE WOOD RTVER
VALLEY
IDAHO POWER COMPANY
REBUTTAL TESTIMONY
OF
DAVID M. ANGELL
CASE NO. IPC_E-L6_28
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O. Please state your name and business address.
A. My name is David Ange11. My bus j-ness address
is 7227 West Idaho Street, Boise, Idaho 83102.
O. By whom are you employed and in what capacity?
A. I am employed by Idaho Power Company ("Idaho
Power" or "Company") as the Transmj-ssion and Distribution
Planning Manager.
O. What j-s the purpose of your rebuttaf testimony
in this proceeding?
A. Idaho Public Utilities Commissi-on Staff
("Staff") wltness, Michael Morrison, and Idaho Sj-erra Club
witness, Michae1 Heckler, both conclude that a redundant
transmission l-ine in the North Valley is not needed to meet
the Company's obligation to reliably serve customers. The
purpose of my rebuttal testimony is to describe how Idaho
Power plans, designs, builds, and operates its transmission
and distribution system incorporating concepts and
requirements for redundancy in order to meet its obligation
to reliably serve retail- customers. I will- al-so respond to
several- items raised by Mr. Heckl-er in his direct
testimony.
I. TRJATISMISSION A}ID DISTRIBI'':TION PI,AI{NING
AI{D DESIGT{ STA}.iIDARDS
O How does the Company plan the transmission and
25 distribution system for retail customer service?
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A. Transmissi-on and distribution planning is
focused on supplying sufficient capacity in a rel-iabl-e and
cost-effective manner.
The capacity of the system is sized in a similar way
as transportation systems, such that there are large
capacity components that provide transport for generation
to J-arge geographical areas, where it then connects to a
network of smal-l-er capacity components, ultimately
delivering energy to the end-use retail- customer. An
example of this is the high capacity 230, 345, and 500
kil-ovolt (*kV") transmission system that connects the
generation source to hub substations located near Jerome,
Eden, and Hagerman in the Magic VaIIey. The voltage is
reduced through transformation at each of these substati-ons
to 138 kV. The 138 kV transmission lines distribute power
to distribution substations within the Magic and Wood River
Valleys. Distribution substations further reduce the
voltage to 72.47 and 34 .5 kV for distribution within l-ocal
communities to the end-use customer.
The capacity requirements are determined through
historical customer peak demand and projections
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ofanalysis
of future demand, taking
reductions and
into account both energy
23 ef f J-ciency growth in industrial, commercial,
Historical demand is captured24 and resi-dential customers.
25 and adjusted to account for extreme temperature events to
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Idaho Power
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ensure sufficient capacity i-n the system to meet the peak
demand during these infrequent weather conditions.
O. When are capacity additions made to the
transmission and distrj-bution system?
A. The Company's planning engineers identify
capacity additions five years j-n advance of the forecasted
need. Demand and customer additions are closely tracked
during this period to optimize the timing of the capacity
addition.
O. Does the Company involve
in the planning process?
A. As described in my direct
the local community10
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Company invofves the local community in
l-ocation of the facilities required to
testimony, the
planning the
meet future
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el-ectrical demand. Electrlc plans are developed wlth the
communities and are publicly available on the Company's
website. The e1ectric plans identify specific transmission
and substation projects along with their anticipated in-
service date.
O. How is transmj-ssion, distribution, and
substation rel-iability planned and designed for in the
system?
A. Reliability is consj-dered when planning the
capacity additions, and is based upon fundamental concepts
of redundancy and not having all of your eggs in one
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Idaho Power
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basket. The system is designed in such a way that it can
and does evolve and grow as it expands with the growth and
change of the customers and load it serves. Rel-iability is
greatly improved and enhanced by the abiJ-ity to limit
outages to smal-l-er segments of customer populations and by
having more than one source of energy available that can
take over when the primary source is interrupted. The
Company has establ-ished design standards, or criteria for
capacity additions to the system and the design of
necessary upgrades or additions to transmission and
distribution lines, and substations that enhance
reliability and j-ncorporate these concepts of adequate and
reliable service balanced with cost.
A new substation is typically energized with a
single transmj-ssion line, single transformer, and two or
three distribution circuits that could serve up to 30
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circuit is
("MW") of customer 1oad. Each distribution
1B configured to serve up to 10 MW of customer load
19 to limit the number of customers impacted by a circuit
20 outage. When feasibl-e, tie switches are installed between
2l circuits to allow customer load transfers to other circuits
22 when an outage occurs on the primary circuit. As l-oad
23 grows for a substation that is energized with a single
24 transmission line, two things happen: eventually, a
25 capacity addition will be required to serve growing load;
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Idaho Power
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l- and the risk and consequences associated with service
dj-sruption and potential long-term outage increase. Once
peak l-oad at a single substation is projected to exceed 40
MW, Idaho Power planning standards require a second
transmission source and transformer to provide the
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and service to customers.
give other examples of how the
principles of mitigating exposure
a part of how Idaho Power's system is
and operated?
The Company has selected 44.8 MVA as the
of the substation.As stated, the
MW from a single
engineers forecast
they propose the
to serve up to 40
necessary
o
referenced
reliability
Can you
fundamental
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and redundancy are
planned, designed,
A. Yes.
load service l-evel-
Company standard is
transmission l-ine.the planning
exceed 40 MW,
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L2 largest distribution substation transformer to be
13 instal-led. A maximum of four distribution circuits are
14 connected to a transformer. This configuration limits the
15 number and amount of customer l-oad impacted by a
16 transformer outage to 40 MW. Additionally, the Company
71 also limits distribution substations to 100 MW of load
18 service before a new substation j-s required.
79 O. What is the transmisslon configuration for a
20 distribution substation?
2L A. The transmission configuration depends on the
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Idaho Power
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1 addition of a second transmission line
line will connect into the transmission
O. How does the North VaIJ-ey
Company's transmission and distribution
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and specify how that
network.
fit within the
planning criteria?
A As stated in my direct testimony, Idaho Power
generally
source and
projected to exceed
planning and design
addltions of second
initiates and constructs a second transmission
transformer when a substation peak load is
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40 MW pursuant to prudent utility
criteria. Recent examples include the
transmission l-ines and transformers at
substation south of Boise and the McCal1
McCaIl, Idaho. Idaho Power is also moving
a second transmission project in the EagJ-e and
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the Victory
substation an
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Star area, which peaks at 7t MV[. The area north of Hailey,
served by the Ketchum and Elkhorn substations, represents
the second largest customer base in Idaho Power's service
territory served by only a single transmission line. The
Ketchum and Elkhorn substations' peak load of about 60 MW,
coupled with the winter tourism population in the North
Val1ey and the mountainous terrain with difficult access to
the existing line, strongly supports the need for a second
transmissi-on line.
O. Are there other simil-arl-y situated areas of
customers as that of the North Valley served by a redundant
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Idaho Power
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25 transmission source?
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A. Yes. The proposed
for the North Va11ey is similar
transmission configuration
to that serving McCaIl and
the north ltiood RiverSalmon, two remote
ValJ-ey. The McCall-
transmission lines
communlties like
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substation.
There are many
serving substations in
and Pocatello service
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13 all cases, the Company plans
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The Salmon area substations are served by two 69 kV
transmi-ssion l-ines that are sourced from the Agency Creek
substation is served by two 138 kV
that connect to the Starkey substation.
short 138 kV transmission lines
the Treasure Va1Iey, Magic Va11ey,
areas with reliability performance
Wood River-Ketchum line. In
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substation peak
demand is forecasted to exceed 40 MW to all-ow for planned
and unplanned outages of transmission and substation
facilities.
O. Is it typical for util-ities to establish
redundant transmi-ssion criteria for distribution
substations ?
Yes. Each utility establ-ishesA
the system
when any
for the addi-tion of
planning
configurations
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22 criteria that include redundant transmission
23 for distribution substations. The three Northwest
24 investor-owned util-ities that serve customers in Idaho al-l-
25 have reliability criteria regarding redundant service that
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is consistent with Idaho Power's criteri-a. Idaho Power
initiates and constructs a second transmrssron source and
transformer when
for
peak l-oad is projected to exceed 40 MW.
a second transmission l-ine at a threshol-dAvista plans
of 75 MW, but
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Mountain Power
is currentl-y reducing that threshold. Rocky
does not have a specific l-oad l-evel- trigger
but evafuates peak l-oad with outage probability and
duration, where the outage duration is based on an
estimated repair time considering terrain and access
difficutty. Northwestern Energy adds a second transmission
Ii-ne when the substation demand exceeds 20 MW.
O. May utilities establ-ish their own criteria for
transmiss j-on reliabil-ity?
A. The Eederal- Energy Regulatory Commission
(*FERC") has jurisdiction over the reliability of the bulk-
power system. Utiliti-es must design, construct, and
operate their systems consistent with FERC requirements,
and thus util-ities establish criteria designed to meet the
FERC reliability requirements. Utility criteria may vary,
as referenced above, but is bounded by the standards
establj-shed by EERC. FERC regulation of reliability
standards was established in the Energy Policy Act of 2005
f ol-Iowing the 2003 eastern interconnection blackout. The
2005 Act required FERC to certify an Electric ReJ-iability
Organization (*ERO"), whose purpose is to establish and
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enforce reliability standards. FERC certified the North
American El-ectric Reliability Corporation ("NERC") as the
ERO.
O. Are there standards for planning the
transmission system with respect to transmj-ssion l-ine
outages ?
A. Yes. The NERC Transmiss j-on System Planning
Performance Requirements Rel-iabil-ity Standard, approved by
FERC on October 17, 20L3, addresses how transmission
planning engineers must plan the bul-k-power system so that
it meets performance requirements over a broad spectrum of
system operating conditions and fol-lowing a wide range of
probable transmission facility outages. One objective of
the standard is for the transmission planning engineers to
design the system to minimize the likel-ihood and magnitude
of firm transmission service interruptions, or non-
consequential load l-oss, following a facility outage due to
a short circuit within a line, transformer t or generator.
O. Is there a limit to the planned amount of non-
consequential
outage due to
or generator?
A.
l-oad loss allowed for a single facility
transformer,a short circuit within a line,
Yes. NERC has established reliability
l-oss for the loss
loss of two
24 standards for the non-consequential load
25 of a single transmission line and for the
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transmission l-ines. The standards account for the
probability of an event.
transmission lines at the
probabllity than the l-oss
NERC reliability standards
Because the loss of two
same time has a much lower
of one transmission line, the
allow for
the loss
a single
of 75 MW.
unl-imited non-
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consequential load l-oss
l-ines. The upper l-imit
non-consequential load
non-consequential l-oad
upon upper bound to the
single facility outage.
for
for
l-oss
loss establ-ishes
amount of load
of two transmission
transmi-ssion line is a
The 75 MW limit to
a national-ly agreed
to be at risk for a
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The Company's approach of limiting
by a single transformer to 40 MW,
conversion of substations from
servlce, as a
exceed this
along
radial
with planning for
to network connectivity with redundant
prudent utility practice desj-gned to meet and
national standard.
tl O. Staff witness Michael Morrison ultimately
18 concludes that there is no demonstrated need for a
19 redundant l-ine, essentially arguing that the existlng
20 radial l-ine is sufficiently rel-iable on its own and that it
27 is too expensive to provide redundant facllities. fs this
22 consistent with prudent utility practices of system design
23 and the leve1 of reliabil-ity expected of the Company in its
24 provision of essentj-al servj-ce to the public?
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A. No, Idaho Power designs its system to meet
certaj-n reliabil-ity and service quality standards that are
consistent with other utilities as well as national
standards. When these criteria for upgrades or additions
are met, al-l- of which are met by the current situation in
the North Valley, redundant service is provided to reduce
the rj-sk, cost, and potential damage to the public from
interruption of service or long-term outage. The North
Val1ey area has grown to such a size, is relatively remote
with difficult to access facilities, and has a substantial
seasonal resort economy that the risk of harm from a
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potential
effects of
conditions
long-term outage and the potential catastrophic
a long-term outage during extreme winter
when North Va11ey el-ectric load peaks is too
served by a singJ-e, radial feed-no matter how15 great to be
L6 rel-iabl-e that single transmissj-on line may have been in the
L7 past.
l-8 The redundant transmissi-on source is the most cost-
1,9 effective means of providing the required reliability
20 improvements and mitigation of potentially damaglng outages
2l in the North Valley. Idaho Power eval-uated severaf other
22 sources of alternative or addj-tional generation for the
23 North Va11ey, which I will- address next j-n my response to
24 severa] of Mr. Heckler's issues.
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II. RESPONSE TO IDAIIO SIERRA CLI'B
Idaho Sj-erra Club's witness, Mr. Michael-
advocates that other sol-utions besides that of
a second transmission line would be better and
Heckler,
building
provide
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more cost-effective reliability solutj-ons. Heckler
Direct, p. 2. He states that the Company has errors and
misrepresentations in the terminol-ogy used with regard to
"reliability" "redundancy" and "proximity" stating that
"redundancy is not the need itself. Reliable service is
the need." Heckl-er Direct, p. 5. fs the proposed
redundant transmission line r or redundancy, the need in and
of itself as Mr. Heckler has portrayed?
A. Not exactly. The need j-s to provide adequate
and reliabl-e electrical service in a cost-effecti-ve manner
to the public, includlng essential services. As stated, a
fundamental design principle in the electric utility
industry is to meet reliability through providing
redundancy and spreading exposure across multiple smal-l-er
facilities rather than being completely reliant on a single
facility. In my direct testj-mony on page 2, l-ine 13, I
address the need as the "obligation to provide adequate and
reliable service" and I then further clarify the need on
lines 20 and 21 as "j-ncreased reliability provided by a
redundant source of energy. " These statements
differentiate that the need is for redundancy of energy
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1 supply in order to provide reliab1e service. The proposed
2 transmission l-ine is not requj-red to address a forecasted
3 peak demand beyond the capacj-ty of the existing
4 transmission line. However, Mr. Heckler has identified one
5 of the larger questions in this case that the ldaho Public
6 Utilities Commission must determine: Does the Company's
7 obligation to provide reliable service to the public in the
B North Valley require a second transmission line as a source
9 of energy j-n order to mitigate the risk posed by an
10 extended outage of the current radial service to public
11 safety, essential servj-ces, businesses, and property
72 damage. This issue is discussed further in fdaho Power's
13 rebuttal testimony of N. Vern Porter. No matter how good
14 the reliability is of the existing l-ine, the North Valley
15 remains exposed to the risks associated with long-term
16 outage to that single l-j-ne unl-ess and until a redundant
L1 sourcer ot second line, is avail-able. NERC reliability
18 standards embody the concept of redundant service and
19 el-imination of radial- service as required reliability
20 improvements.
27 The Company has an obligation to provide service
22 that meets customers' demand as it may vary throughout each
23 day and season. As stated above, the Company also plans
24 for increasing reliability of service when the aggregate
25 peak demand exceeds 40 MW. The Company has evaluated
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1 multiple options to supply the peak demand as provided in
2 my direct testimony, and a second transmission source is
3 the most cost-effectlve reliability solution for the risk
4 exposure in the North Va11ey.
5 Q. Mr. Heckl-er then addresses "redundancy" and
6 "proximity" concluding that "the proposed redundant l-ine
7 will not provide an independent source of energy as the
8 Company purports." Is this correct?
9 A. No. The "proximity" issue raised by Mr.
10 Heckler refers to my direct testi-mony on page 29 where I
11 describe a double circuit option on a common tower
72 configuration from the El-khorn substation to the Ketchum
13 substation across the top of Dol-Iar Mountain. Mr. Heckler
74 then attempts to equate this double circuit/common tower
15 configuration with the proposed l-ine route where, in his
16 words:
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The Company's proposed route is not free
from the stated problem of having two lines
being in close proximity of each other. The
proposed line would cross the existing WDRI-
KCHM line within a quarter mil-e of where
both lines l-eave their coflrmon source at the
WDRI substation. Moreover, there are never
more than a few hundred yards separating thetwo lines for the first few mil-es of their
routes north of WDRI.
Heckler Direct, p. 1.
First of all, it j-s not true that the proposed line
and the existing line cross. They do not cross, nor do
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1 they share common towers. Secondly, "proximity" 1s not
2 prohibited nor addressed by NERC reliability standards
3 beyond a common tower configuration. The double circuit
4 option on a common tower configuration from the Elkhorn
5 substation to the Ketchum substation across the top of
6 DoIlar Mountain referenced in my testimony was eliminated
7 based on transmission planning consistent with NERC
8 standards TPL-001-4, ds that configuration has a higher
9 probability of simultaneous circuit loss than separately
10 constructed transmission lines. Unl-imited non-
11 consequential l-oad loss is allowed by NERC standards for
72 these events because they have a lower probability of
13 occurrence than l-oss of a single transmission lj-ne.
!4 O. Mr. Heckl-er also states that the substation is
15 a single poj-nt of failure. Does the fact that both
t6 transmission Iines originate in the same substatJ-on, the
L7 Wood River substation, destroy the reliability improvements
18 of the second transmission source?
19 A. No. The rel-iabil-ity gains come from
20 elimination of the single radial- source north of the V{ood
2! River substatj-on. The rel-iabil-ity of the "source"
22 substation, in this case the Wood River
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facilities. The
substation, woul-d
Wood Riverbe addressed with other
substation, itself, is
transmlssi-on sources of
sourced by two redundant
energy. Additionally, there are
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1 many significant differences when considering the
2 rel-:-abllity and repairability of substations versus that of
3 transmission and distribution lines. Substations are
4 constructed with steel supporting structures, have much
5 l-ess exposure to l-ine events, and their failure occurs much
6 less frequently than transmission lines. Substations, like
7 the Wood River substation, have remote monitoring and
8 control equipment, which aIl-ows for quick identificatj-on of
9 a failure, remote reconfiguration, and dispatch of
10 personnel- to a known location. Additionally, the Wood
11 River substation is located just north of Hail-ey next to
L2 Highway 75 and is much more easily accessed than portions
13 of the existing transmission line.
1,4 O. Do the referenced planning standards address
15 outages within a substation or simul-taneous l-oss of l-ines?
16 A. Yes. The planning standards address failures
t1 of components within a substation but not the l-oss of the
18 entire substation. They also address the loss of two
19 transmission circuits. In both cases, unl-imited non-
20 consequentlal l-oad loss is al-l-owed for these events because
2L they have a fower probability of
transmission line outage.
O. Mr. Heckler states
occurrence than a single
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24 justifying the redundant l-ine based on an
Company is
assumpti-on of
23 that the
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1 future load growth. Is this true and how does he come to
2 this concLusion?
3 A. No. The purpose of the redundant transmission
4 l-ine is reliable service and, as I stated earlier, the
5 proposed transmi-ssion l-ine is not required to address a
6 forecasted peak demand beyond the capacity of the existing
7 transmission line. Mr. Heckl-er's argument in this section
I of his testj-mony has misinterpreted or misrepresented the
9 information contained in the Wood Ri-ver Electrical- Pl-an.
10 First, the plan is designed to identify the electrical
11 facilities required to meet the ultimate demand of the
72 pJ-anning area. The process uses two separate approaches to
13 identify the eventual- peak el-ectrical demand when the
L4 available private land is ful1y developed consistent with
15 the area's .l-and use planning. Second, the plan presents a
L6 1ike1y time frame that the identified infrastructure
77 improvements are to be constructed.
18 O. Do you agree with Mr. Heckl-er's assertion of
19 using inappropriate techniques in analyzing l-oca1 backup in
20 the Northern Wood River Va11ey - Local Backup Electrical
2L Supply Report?
22 A. No. Customers regularly read artlcles about
23 energy technology and ask whether the Company is pursuing
24 those technol-ogies. This most recent analysis, Exhi-bit No.
25 3 to my direct testimony, was prompted by a Wood River
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1 Valley resident interested in an analysis of the l-ocal
2 energy options. A team of Company engineers gathered data
3 on availabl-e energy resources and referenced prior solar
4 generation and property protection analysis. The report
5 presents the resul-ts of a preliminary study to provide the
6 northern Wood River Va11ey customers served by the Ketchum
7 and Elkhorn substatj-ons with backup electrical- supply from
8 loca11y-sited generation. The resources considered in the
9 study are a dlesel reciprocati-ng engine, natural gas
10 combustion turbines, a photovol-taic plus battery energy
11 storage system, geothermal generation, and biomass
12 generation.
13 The analysis was performed using j-ndustry-standard
L4 energy resource simulation software, HOMER@, which was
15 developed by the National Renewabl-e Energy Laboratory
16 (NREL) . The capital, operatj-ons and maintenance (OeUl , and
77 fuel- cost estimates for the resources identified above were
18 obtained from Lazard's Level-ized Cost of Energy Analysis-
19 Version 9.0 (Lazard 2015a). Idaho Power afso compared the
20 Lazard estimates with pre-engineering budgetary quotes from
27 several vendors. Additionally, the Idaho National
22 Laboratory (INL), with more than 1,000 MW of hybrid power,
23 solar, and wi-nd energy systems deployed at Department of
24 Defense and industry/utiJ-ity sites around the wor1d,
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provided independent technical review and feedback on the
analysis and report.
O. Mr. Heck1er asserts that the wrong baseJ-ine is
used by compari-ng
transmission l-ine
this correct?
A. No.
compared
sel-ection of assumptions was
10 of load service levels of
L4
al-ternatives against the redundant
and using hypothetical- conditlons. Is
The Local- Backup Electric Supply Report
l-ocal- generation and storage
based on
peak wj-nter,
Ioads. The
is electric
options. The
the team's definition
property protection,
Wood River Va11ey
supply during winter
could result in
11 summer peak, and crj-tical
12 residents' primary concern
13 condj-tions when a long duration outage
15
water damage following frozen pipes, named Property
Protection by the team. Consistent with the Company's
planning approachr dn extreme average temperature of -2L" F
was sel-ected from historical- data to ensure adequate
capacity during these infrequent large demand periods. An
analysj-s of the residence cooling rate identified that
1,6
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20 rotating distribution circuit service, a\k\a rotating
avoid frozen2l outages, will
22 pipes for al-l-
23 load profile
24 peak but not
25 determine the
not maintain adequate heat to
customers. The December 31, 20L5, 24-hour
of 1,l-50 megawatt-hours ("MWh") was a recent
the extreme temperature event used to
rate of residential- heat loss. Additionally,
ANGELL, REB
Idaho Power
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supplying onl-y
the residents'
critical- loadsr ds suggested, woul-d not meet
need for electricity to maintain heat and
keep pipes from freezing.
The local supply duration was informed by the
estimated time to replace a remote failed structure during
the winter, and the expected time to receive fuel based on
t_0
the following
assessment of
transport in the adverse
in the report, page 11 of
components: line patrol to find the failure,
restoration time, fuel purchase, and
winter weather. Thus, ds stated
56 of Exhibit No. 3, the December
11 31, 2015, 24-hour load profile of 1,150 MWh was used merely
12 to determine a base cost.
13 O. Mr. Heck.l-er next asserts that the wrong costs
L4 were used. Do you have a response?
15 A. As described in the report, the generatj-on and
16 storage technology costs were gathered from several-
L7 sources. Mr. Heckler's Tesl-a PowerWal-I prices of $250 and
18 $450/kil-owatt-hour ("kl/ilh") are not supported based on
19 Tesla's pricing on its website. At the time of the report,
20 Solar City woul-d instal-l- a Tesla PowerWall for $1TLlkwh.
27 Tesla has recently reduced the instal-l-ed cost to a range of
22 $500 to $585/kwh, https: / /www.tesl-a.com/powerwalI. The
23
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industrial-/utility scale PowerPack is sol-d in the same
pri-ce range. The Company recently contacted Tesl-a about
pricing for a project in Oregon and was told that the
ANGELL, REB
Idaho Power
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PowerPack was not currently distributed in Idaho Power's
service territory. However, an instal-led cost would be
increased by 1and, site preparation, and interconnection.
Mr. Heckl-er suggests that the Company analyze
reciprocating engines similar to those evaluated in the
l-0 based on the area's
11
higher l-and costs,
contingency basedtwo locations, and a
preJ-iminary estimate.
Regarding Mr.
Integrated
engines is
Exhibit No.
footnote 34
the logistics of
interconnect ion,
Resource PIan. The cost for
contained in row 1 of Table
3. The cost referenced in
of $775lkilowatt ("kW") was
recrprocating
1 on page 9 of 56 of
Mr. Heckler's
adjusted to $800/kW
interconnection in
appropriate for a
t2
13 Heckler's proposal of storing the 2 MW
14 generators in Pocatello for dispatch to areas of need, the
15 Company's analysis was preliminary in nature and did not
L6 consider how the diesel- generators were configured. The
71 estj-mate of $800/kW may still be appropriate for 2 Mw semj--
18 trailered units. However, unlike locally instal-led units,
19
20
winter transport, placement,
and startup under col-d l-oad
21- conditj-ons woul-d be extremely difficult and
22
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the Property Protection defj-ned need.
Mr. Heckler also asserts that combinations of
Distributed Energy Resources ("DERs") shoul-d be evaluated.
The concl-usj-on of the report identified diesel engines as
pickup
1 i kely
ANGELL, REB
Idaho Power
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the least costly local generatJ-on option. Referring to the
past several- Integrated Resource Pl-ans, the l-east-cost
resource addj-ti-ons have been the Boardman to Hemingway
transmissj-on project followed by reciprocating engines.
Any combination of other DERs wil-l- resul-t in a
significantly higher cost without delivering a benefit to
support the increased cost.
v Mr. Heckler al-so states that technol-ogy has
advisory committeechanged substantially
shoul-d be convened to evaluate distributed resource
and bel-ieves an
10
11 alternatives. Do you agree?
12 A. No. Advances in the production and the
13 increased volume of photovoltaic and battery sal-es have
14 reduced their prices dramatically over the past decade.
15 However, today their costr dS shown in my testimony, the
76 referenced report, and Idaho Power's Integrated Resource
7'7 PIan, are not yet competitive with conventional- technology.
18 The cost differences are so large between conventional- and
19 new technologies for an appreciable amount of energy
20 production or storage that it would be highly unlikely that
2l an advj-sory commj-ttee would develop a different outcome,
22 and I do not agree with this recommendatj-on.
23 O. Does this conclude your testimony?
24 A. Yes.
25
ANGELL, REB
Idaho Power
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AETESTAIIOII OF TESIIMONY
STATE OF IDAHO
SS.
County of Ada
10
I, David M. Ange11, having been duly sworn to
testify truthfully, and based upon my personal knowledge,
state the following:
I am employed by Idaho Power Company as the
Transmissj-on and Distribution Planning Manager and am
competent to be a wj-tness in this proceeding.
I declare under penalty of perjury of the l-aws of
the state of Idaho that the foregoi-ng pre-filed testimony
is true and correct to the best of my lnformation and
belief.
DATED this 23'd day of June 207't .
11
L2
13
t4
15
!6
L1
18
19
20 David M. Angel1
2t
22 SUBSCRIBED AND SWORN to before me this 23'd day of
June 2017.23
24
25
26
21
28
g{AS t'Notary P l-ic for Idaho
go?{4
rDla
Residing at:Boise, Idaho
t My commissi-on expires:02/04/2021
!{rg l
F1
ANGELL, REB 23
Idaho Power Company
,5
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CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 23'd day of June 2017 I served a true and
correct copy of the REBUTTAL TESTIMONY OF DAVID M. ANGELL upon the following
named parties by the method indicated below, and addressed to the following:
Commission Staff
Daphne Huang
Camille Christen
Deputy Attorneys General
ldaho Public Utilities Commission
47 2 \N est Wash ington (83702)
P.O. Box 83720
Boise, ldaho 83720-007 4
Sierra Glub
Kelsey Jae Nunez
KELSEY JAE NUNEZLLC
920 North Clover Drive
Boise, ldaho 83703
Zach Waterman
Director, ldaho Sierra Club
503 West Franklin Street
Boise, ldaho 83702
Michael Heckler
3606 North Prospect Way
Garden City, ldaho 83714
Kiki Leslie A. Tidwell
Peter J. Richardson
RICHARDSON ADAMS, PLLC
515 North 27th Street (83702)
P.O. Box 7218
Boise, ldaho 83707
Kiki Leslie A. Tidwell
300 Let'er Buck Road
Hailey, ldaho 83333
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Rock Rolling Properties, LLC, and
Rock Rolling Properties #2, LLC
Gregory M. Adams
RICHARDSON ADAMS, PLLC
515 North 27th Street (83702)
P.O. Box 7218
Boise, ldaho 83707
Rock Rolling Properties, LLC
Rock Rolling Properties, LLC
c/o Kris Dondero
P.O. Box 739
Sun Valley, ldaho 83353
Rock Rolling Properties #2, LLC
Rock Rolling Properties #2, LLC
c/o John Dondero
P.O. Box 739
Sun Valley, ldaho 83353
City of Ketchum
Matthew A. Johnson
Wm. F. Gigray, lll
WHITE PETERSON GIGRAY
& NICHOLS, P.A.
5700 East Franklin Road, Suite 200
Nampa, ldaho 83687
lndividual
Laura Midgley
231 Valley Club Drive
Hailey, ldaho 83333
CoxGom, LLC
C. Tom Arkoosh
ARKOOSH LAW OFFICES
802 West Bannock Street, Suite 900
P.O. Box 2900
Boise, ldaho 83701
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Christa Bearry, Legal Assistant