20180223Angell Surrebuttal.pdf

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BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OE THE APPLICAT]ON
OF IDAHO POWER COMPANY FOR
AUTHORITY TO ESTABLISH NEW
SCHEDULES FOR RESIDENTIAL AND
SMALL GENERAL SERVICE CUSTOMERS
WITH ON-SITE GENERATION.
CASE NO. IPC_E_17_13
]DAHO POWER COMPANY
SURREBUTTAL TESTIMONY
OF
DAVID M. ANGELL
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O. Please state your name.
A. My name is David M. Ange11.
O. Are you the same David M. Angell that
previously presented direct and rebuttal- testimony?
A. Yes.
O. What is the purpose of your surrebuttal
testimony?
A. The purpose of my surrebuttal testimony is to
respond to Idaho Cl-ean Energy Association's witness Kevin
King's recommendation to wait to make changes to the net
meterj-ng service until the total- nameplate capacity of
residentj-al solar net metering reaches 60 megawatts ("MW").
O. Pl-ease summarize the recontmendation made by
Mr. King rel-ated to the 60 MW namepl-ate capacity of
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residential-
A.
recommends,
should not
capacity
benchmark
o.
of
solar net metering.
In his rebuttal testimony, Mr. King
"That any changes to net metering rate policy
go into effect until after the total nameplate
net metering residential sol-ar reaches a
level- of 6OMW."1
27 When would you estimate that Idaho Power
22 Company ("Idaho Power" or "Company") woul-d reach a total
23 nameplate capacity of 60 MW for residential solar net
24 metering?
1 King DI, p. 10, 11. 7l-12
ANGELL, SURR REB 1
Idaho Power Company
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A. I bel-ieve that ldaho Power will reach a total
nameplate capacity of 60 MW for residential- solar net
metering in 2020. When considering the 1ikeIy year or more
it would take for multiple util-ities and stakehol-ders to
coalesce on the costs and benefits of di-stributed
generation ("DG") in a general docket, I bel-ieve that by
the time this case and a general docket are concluded and
implemented, the Company wil-l- be nearing a cumulative 50 MW
of residential solar net metering installations and
10 applications.
o.How were11
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you abl-e to conclude that the total
residential sofar net metering wil-lnamepJ-ate
reach 60
capacity for
MW in 2020?
A. To estimate when the instal-l-ed capacity for
residential solar net metering might reach 60 MW, the
Company applied a fourth order polynomial curve fit to the
cumulative installed capacity of active and pending
residential sofar instal-lations from 2012 to January 31,
20L8. As shown in Eigure 7, the trend l-j-ne reached 60 MW
after January 2020 but before July 2020.
ANGELL, SURR REB 2
Idaho Power Company
1 Figrrre 1. Trend Line for Idaho Residential Solar Capacity
80,000
70,000
60,000
50,000
! +o,ooo
30,000
20,000
10,000
O. Do you agree with Mr. King's recommendation to
wait to make changes to the net metering rate policy,
including the requirement for smart inverters, until- the
total nameplate capacity of net metering residential- solar
reaches 60 MW?
A. No. There is no need to set an arbitrary
capacity threshold. I bel-ieve that by the time thj-s case
and a general-docket woul-d be concl-uded and implemented,
the Company will be nearing a cumulative 60 MW of
residential solar net metering installations and
applications.
ANGELL, SURR REB 3
Idaho Power Company
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1 Q. What would the operational consequences be of
2 waiting to make changes to the requirement for smart
3 inverters until the total nameplate capacity of net
4 metering residential solar reaches 60 MW?
5 A. The Company has determined that, without the
6 smart inverter requj-rement, voltage impacts may result on
7 certain distribution circuits due to distribution circuit
I DG penetration prior to reaching 60 MW of net metering
9 residential sofar. Voltage impacts would be identified
10 during the study of additional DG installation and woul-d
11 require customer-funded mitigation before the DG coul-d be
72 install-ed and operated.
13 O. How did the Company determine that there would
74 be voltage impacts on certain circuits wlthout the smart
15 inverter requirement?
76 A. A hosting capacity cal-cul-ation program
tl developed by Electric Power Research Institute (*EPRI") and
18 named Dlstribution Resource Integration and Value
19 Estimatlon TooI (*DRIVE") was used for this analysis. Six
20 hiqh DG penetration distribution circuits were model-ed in
27 DRIVE. These model-s incl-uded customer 1oad, customer
22 generation, and Idaho Power voltage management devj-ces.
23 The voltage threshol-ds were set at American National-
24 Standard Institute (ANSI) C84.1, Efectric Power Systems and
25 Equipment-Vol-tage Ranges, Range A tolerances of plus or
ANGELL, SURR REB 4
Idaho Power Company
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minus 5 percent. The
which caused a voltage
addition of DG on the
standard inverters and
program identified the DG
with smart inverters, conformlng to
the proposed fEEE-L541 standard, to determine the remaining
hosting capacity under each scenario.
O. What were the results from the analysis of the
two cases?
A. Two-thirds of the distribution circuits
analyzed wou1d be abl-e to host more DG if smart inverters
are installed with reactive support capability enabled.
Without the aid of smart inverters and assuming the high DG
penetration circuits continue to maintain their high ratio
A The condition was that the localized high
of nomlnal- voltage.20 voltage conditions exceeded 105 percent
2l This condition occurs when one or more lnverters are
24 O How wiII
25 mitigate these impacts
threshold to be exceeded
capacj-ty
due to
run withcircuit. Simulations were
into the dlstribution circuit during periods
ener9y usage.
the requirement of smart inverters
to the grid?
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L4 of installations refative to other circuits, four of the
15 si-x circuits would be limited before the proposed 60 MW
reached.76 system threshold is
71 What was the condition that ]imited the
18 hosting capacity on these dlstributlon circuits?
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sourcing power
of low customer
ANGELL, SURR REB 5
Idaho Power Company
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A. The smart inverters with voltage control-
enabl-ed woul-d mitigate these l-ocal-ized high voltage
conditions as described on page 23 of my direct testimony.
O. In your direct testimony, you stated that the
cost differential between a smart inverter and a standard
inverter for a 6,000 watt system was $120.2 Is that stil-l
true today?
A.Research performed by the Company suggests
The Company's research
A a smart inverter is installed, the smart
be disabled. A tariff23 inverter functionality L-dt1
10 shows that smart inverters are becoming prevalent and most
11 solar inverter manufacturers only offer smart inverter
72 functionality. Of net metering applications received by
13 the Company during the last year, 98 percent of the
14 applications identified inverter manufacturers which offer
15 smart inverter functionality as a standard feature of their
16 product. This would suggest that there is not necessarily
tl an "additional" cost for a smart inverter, but rather the
18 smart inverter is commonly included as a standard feature.
19 O. Why is it necessary to have a tariff
20 requirement for smart inverter functionality if most
that it is no longer accurate
only
When
2l manufacturers offer smart lnverters functionality?
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2 AngeJ-1 DI, p. 24 , l-I . 5-24 .
ANGELL, SURR REB 6
Idaho Power Company
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requirement woul-d ensure that smart inverter functionality
is enabled f or al-l- installati-ons.
0. Please summarize your surrebuttal- test.imony.
A. The Company has demonstrated that delaying
changes to the net metering rate policy, including the
i-mplementation of the requirement for smart j-nverters,
based on an arbitrary capacity threshold will negatively
impact customers' ability to install DG on the distribution
circuits where their neighbors have already instal-l-ed DG.
O. Does this concl-ude your testimony?
A. Yes, it does.
ANGELL, SURR REB 1
Idaho Power Company
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ATTESTATION OF TESTIMONY
STATE OF IDAHO
ac
County of Ada
5 I, David M. Ange11, having been duly sworn to
6 testlfy truthfully, and based upon my personal knowledge,
7 state the following:
8 I am employed by Idaho Power Company as the Senior
9 Manager of T&D Engineering and Construction and am
10 competent to be a wj-tness in this proceeding.
11 I decl-are under penalty of perjury of the faws of
L2 the state of Idaho that the foregoing surrebuttal testl-mony
13 is true and correct to the best of my information and
L4 belief.
15 DATED this 23rd day of February, 2018.
16
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18 David M. Angell
19 SUBSCRIBED AND SWORN to before me this 23rd day of
Eebruary, 20L8.20
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Y r.G*ru
No ry Pub for fdaho
Residing a Boise, Idaho
My commission expiresz L2/20/20
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2B
ANGELL, SURR REB B
Idaho Power Company
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CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 23rd day of February 2018 I served a true and
correct copy of SURREBUTTAL TESTIMONY OF DAVID M. ANGELL upon the
following named parties by the method indicated below, and addressed to the following:
Commission Staff
Sean Costello
Deputy Attorney General
ldaho Public Utilities Commission
47 2 W est Wash in gton (83702)
P.O. Box 83720
Boise, ldaho 83720-007 4
ldahydro
C. Tom Arkoosh
ARKOOSH LAW OFFICES
802 West Bannock Street, Suite 900
P.O. Box 2900
Boise, ldaho 83701
Idaho Conseruation League
Matthew A. Nykiel
ldaho Conservation League
102 South Euclid #207
P.O. Box 2308
Sandpoint, ldaho 83864
Benjamin J. Otto
ldaho Conservation League
710 North 6th Street
Boise, Idaho 83702
ldaho lrrigation Pumpers Association, !nc.
Eric L. Olsen
ECHO HAWK & OLSEN, PLLC
505 Pershing Avenue, Suite 100
P.O. Box 6119
Pocatello, ldaho 83205
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Anthony Yankel
12700 Lake Avenue, Unit 2505
Lakewood, Ohio 44107
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Auric Solar, LLC
Preston N. Carter
Deborah E. Nelson
GIVENS PURSLEY LLP
601 West Bannock Street
Boise, ldaho 83702
Elias Bishop
Auric Solar, LLC
2310 South 1300 West
West Valley City, Utah 84119
Vote Solar
David Bender
Earthjustice
3916 Nakoma Road
Madison, Wisconsin 537 11
Briana Kobor
Vote Solar
986 Princeton Avenue S
Salt Lake City, Utah 84105
City of Boise
Abigail R. Germaine
Deputy City Attorney
Boise City Attorney's Office
150 North Capitol Boulevard
P.O. Box 500
Boise, ldaho 83701-0500
ldaho Clean Energy Association
Preston N. Carter
Deborah E. Nelson
GIVENS PURSLEY LLP
601 West Bannock Street
Boise, ldaho 83702
Sierra Club
Kelsey Jae Nunez
KELSEY JAE NUNEZLLC
920 North CIover Drive
Boise, ldaho 83703
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Tom Beach
Crossborder Energy
2560 9th Street, Suite 213A
Berkeley,CA 94710
Zack Waterman
Director, ldaho Sierra Club
503 West Franklin Street
Boise, ldaho 83702
Michael Heckler
3606 North Prospect Way
Garden City, ldaho 83714
Snake River AIIiance
NW Energy Coalition
John R. Hammond, Jr.
FISHER PUSCH LLP
101 South Capitol Boulevard, Suite 701
P.O. Box 1308
Boise, ldaho 83701
lntermountain Wind and Solar, LLC
Ryan B. Frazier
Brian W. Burnett
KIRTON McCONKIE
50 East South Temple, Suite 400
P.O. Box 45120
Salt Lake City, Utah 84111
Doug Shipley
lntermountain Wind and Solar, LLC
1953 West2425 South
Woods Cross, Utah 84087
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