20210203Reply Commments.pdf

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LISA D. NORDSTROM
Lead Gounsel
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February 3,2021
VIA ELECTRONIC FILING
Jan Noriyuki, Secretary
ldaho Public Utilities Commission
11331 W. Chinden BIvd., Bldg 8,
Suite 201-A(83714')
PO Box 83720
Boise, ldaho 83720-0074
Re: Case No. IPC-E-20-30
ln the Matter of ldaho Power Company's Application forAuthority to Establish
Tariff Schedule 68, lnterconnections to Customer Distributed Energy
Resources
Dear Ms. Noriyuki
Attached for electronic filing, pursuant to Order No. 34602, is ldaho Power
Company's Reply Comments
lf you have any questions about the attached document, please do not hesitate to
contact me.
Very truly yours,
X;!.fl^t t -*,
Lisa D. Nordstrom
LDN:slb
Attachment
LISA D. NORDSTROM (lSB No. 5733)
Idaho Power Company
1221West ldaho Street (83702)
P.O. Box 70
Boise, ldaho 83707
Telephone: [phone]
Facsimile: [phone]
lnordstromtOida hopower.com
Attorney for ldaho Power Company
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF IDAHO POWER
COMPANY'S APPLICATION FOR
AUTHORITY TO ESTABLISH TARIFF
SCHEDULE 68 - INTERCONNECTIONS
TO CUSTOMER DISTRIBUTED ENERGY
RESOURCES.
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CASE NO. |PC-E-20-30
IDAHO POWER COMPANY'S
REPLY COMMENTS
ldaho Power Company ("ldaho Powef' or the "Company") respectfully submits
these Reply Comments in response to the Comments filed by the Staff of the ldaho Public
Utilities Commission ("Staff'), ldaho Conservation League ("lCL"), ldaho Sierra Club
("Sierra Club"), and the ldaho Clean Energy Association, lnc. ('ICEA") on January 13,
2021. ldaho Power appreciates the thoughtful review of the Company's proposa! and the
comments submitted by the parties of record. In ldaho Power's Reply Comments, the
Company will provide additiona! context regarding compliance with Case No. IPC-E-17-
IDAHO POWER COMPANY'S REPLY COMMENTS - 1
13 and respond to recommendations related to (1) smart inverters, (2) the non-export
option, and (3) implementation.
I. BACKGROUND
The Company filed an Application on July 20, 2020, requesting the ldaho Public
Utilities Commission ("Commission") authorization to establish tariff Schedule 68,
lnterconnections to Customer Distributed Energy Resources ("Schedule 68'). The
proposed Schedule 68 is intended to comply with Commission Order Nos. 34046 and
34147 from Case No. IPC-E-17-13, which directed the Company to file smart inverter
requirements within 60 days of the final adoption of lnstitute of Electrical and Electronics
Engineers ("IEEE') standards 1547 and 1547.1, and to study the feasibility of a non-
export option for Distributed Energy Resources ("DER" or "DERs") connection to the
Company's system. The Company requests that Schedule 68 become effective 14 days
after approval by the Commission.
Parties of record filed comments, including Staff, lCL, Sierra Club, and ICEA, on
January 13, 2021. Pursuant to the Notice of Modified Procedure issued by the
Commission in Order No. 34817, ldaho Power hereby submits its Reply Comments
responding to parties' comments and recommendations.
!I. SMART INVERTER SETTINGS
The Company appreciates the thorough review conducted by Staff and the support
for approval of the Company's proposal to both establish Schedule 68 and the
requirements for incorporating smart inverters. In its Comments, Staff "advises that
because the Company does not intend to use the communications protocols specified by
IEEE 1547-2018, smart inverters may not provide all the functionality stated by the
IDAHO POWER COMPANY'S REPLY COMMENTS - 2
Gompany in IPC-E-17-13."1 lt appears Staff relied on the Commission's summary of the
Company's position contained within Order No. 3/1046,2 which was not entirely
representative of the Company's position. Page 566 of the transcript in Case No. IPC-E-
17-13 corresponds to Dave Angel!'s direct filed testimony:
Q. What functions does ldaho Power perform in order to maintain
a safe and reliable distribution system and grid?
A. In order to provide safe and reliable energy on demand, ldaho
Power must perform the following functions: voltage control,
system protection, scheduling, dispatching, and load balancing.
These functions are @mmonly referred to and collectively known as
ancillary services.3
The language Staff cited in its Comments was in response to what functions ldaho
Power performs - the answerwas not referencinq smart inverterfunctions. However, the
Commission's findings that smart inverters provide functionality that is beneficial to
support the ongoing stability and reliability of the Company's distribution system were
based on a correct interpretation of the Company's smart inverter implementation
recommendation. ln Order No. 34046, the Commission stated:
1 Staff Comments, at 4 (emphasis added).
2 ln the Matter of ldaho Power Company's Application for Authority to Establish New Schedules for
Residential and Small General Service Customers with On-Site Generation, Case No. IPC-E-17-13, Order
No. 34046, at 20 ("The Company believes that the benefits of smart inverters include providing important
ancillary services, such as: voltage control, system protection, scheduling, dispatching, load balancing, and
forecasting. Tr. At 566.").
3 Case No. IPC-E-17-13, Angell, Dl, at 4 (emphasis added).
IDAHO POWER COMPANY'S REPLY COMMENTS - 3
The Commission now acknowledges that the weight of the evidence
supports the proposition that smart inverters provide functionality
that is beneficial to support the ongoing stability and reliability of the
Company's distribution system. Therefore, we find that the industry's
adoption of a smart inverter requirement will mitigate circuit voltage
deviation in a cost effective manner and is therefore reasonable.a
This final language from Commission Order No. 34046 aligns with the voltage
control measures that the Company described and requested in Case No. IPC-E-17-13.5
The Company is now requesting to implement only the smart inverter functionality
necessary to maintiain normal operating voltage,6 as the Company presented in Case No.
]PC-E-17-13, and as the Commission found to be reasonable in Order No. 34046. The
Company's proposed settings will improve power quality and provide the opportunity for
customers to expand the interconnection of DERs for the long-term interest of the system
without requiring costly system upgrades to address issues such as voltiage rise.
Therefore, the record supports that the Company's recommendation regarding the
implementation of smart inverters in this case is consistent with the implementation plan
and associated applicable functionality presented by the Company in Case No. IPC-E-
17-13.
The Company appreciates the support in Comments from both Staff and ICL for
the proposed non-export interconnection option. lCL recommends a modification to the
Company's non-export option for systems 3 MVA and larger, suggesting to "only require
additional metering and communications equipment if the site-specific studies reveals this
a Case No. IPC-E-17-13, Order No. 34046, at 20 (emphasis added).
5 Case No. IPC-E-17-13, Angell, Dl, at23 -27.
6 Ellsworth, Dl, at 11-14.
IDAHO POWER COMPANY'S REPLY COMMENTS - 4
is required to avoid unreasonable impact to the system."7 As a point of clarification, the
Company's proposaldoes not intend to create potentially expensive additionalequipment
when it is not required. lnstead, the requirement for metering and communications
equipment is necessary to provide operational visibility of the customer generation to
ensu re critica I system operational fu nctions.s
Visibility is required for scheduling, dispatching, and load balancing.e !n the
Western lnterconnection overseen by the Western Electricity Coordinating Council
('WECC'), Balancing Authorities like ldaho Power are responsible for forecasting future
system loads and resources and maintaining sufficient contingency reserves.lo Actual
data from these customer sites with DERs 3 MVA and larger is criticalfor maintaining and
refining an accurate load and resource forecast. For dispatching, System Operators must
consider whether ANSI standard C84.111 can continue to be met if a large DER system
suddenly reduces output.12 Additionally, for load balancing, System Operators must
maintain a rea!-time balance between system load and system resources to comply with
the North American Electric Reliability Corporation's ("NERC") reliability requirements.l3
Real{ime information about the production of larger system resources, such as DERs 3
MVA or greater, provides important real-time visibility into what may be causing an area
7 ICL Comments, at 3.
8 Ellsworth, Dl, at 23.
e Ellsworth, Dl, at24.
10 WECC Reliability Standard BAL-002-WECC-2, Contingency Reserves.
11 ANSI C84.1-2020, American National Standard for Electric Power Systems and Equipment - Voltage
Ratings (60 Hertz).
12 Ellsworth, DL a|24.
13 NERC Reliability Standard BAL-001-1 , Real Power Balancing Control Performance, Requirement R1.
IDAHO POWER COMPANY'S REPLY COMMENTS - 5
control enor deviation.la ln summary, the Company urges the Commission to approve
Schedule 68 and the non-export option as filed to provide ldaho Power with the necessary
operational visibility for scheduling, dispatching, and load balancing to safely and reliably
manage the Company's system.
IV. SCHEDULE 68 IMPLEMENTATION
ldaho Power offers the following response to ICL's three recommendations
regarding the implementation of Schedule 68:
1) The Company provide simple education materials and training sessions for
all solar installers in ldaho Power's service territory.
2) The Company clariff how it wi!! assure conect software settings for smart
inverters during system inspections.
3) The Company provide annual reporting to address the growth of DERs
interconnected on the Company's system.15
1. Education and Traininq: The Company agrees with ICL that education and
training for installers in its service area concerning the requirements of Schedule 68 will
be necessary. ldaho Power contends that this outreach is vital to facilitating a streamlined
transition to the new interconnection requirements for customer DERs. The Company
has developed a plan to provide communication materials to all known installers in ldaho
Power's service area if Schedule 68 is approved by the Commission. Communication
materials will include email notices, as well as updated materials on the Company's
1a Ellsworth, Dl, at24.
15 ICL Comments at 3-4.
IDAHO POWER COMPANY'S REPLY COMMENTS - 6
website. Additionally, the Company plans to offer virtual training sessions with installers
to review the interconnection requirements and answer questions.
2. Smart Inverter Settinqs: Pursuant to the proposed provisions of Schedule 68,
a customerl6 must provide the Company with a completed System Verification Form
detailing the specifications of all installed components of the completed customer
generation system. As a genera! practice, the Company intends to rely on the customer's
self-certification to assure correct software settings have been implemented; however, if
necessary, will request the customer provide documentation.
3. Annual DER Reportinq: ICL recommends that ldaho Power provide annual
reporting to address DER systems' growth within its service area. Specifically, ICL
suggests describing DER levels, any impacts to distribution circuits, and the potentialfor
additional smart-inverter-based functions, ultimately recommending ldaho Power could
include the update in its annual Demand-Side Management report.17 While not opposed
to providing more information on non-exporting DER growth and any system impacts, the
Company believes any additional DER reporting is more appropriately included in the
Company's annua! Net Metering Report.18
V. CONCLUSION
ln consideration of the foregoing, ldaho Power respectfully requests the
Commission issue an order approving the Company's proposed Schedule 68 as filed.
16 ln practice, the System Verification Form is often submitted by the installer acting as the customer's
agent.
17 ICL Comments, at 4.
18 Pursuant to Order Nos. 32846 and32925 issued in Case No. IPC-E-12-27,ldaho Power submits an
annual report updating the Commission on participation levels and growth rates in on-site generation,
system reliability impacts, and updates on meter aggregation activity. The Company will file the next report
on or before April 30, 2021.
IDAHO POWER COMPANY'S REPLY COMMENTS - 7
With respect to parties' other recommendations, ldaho Power believes that: (1) ldaho
Power's proposal for smart inverter requirements is consistent with all functionality stated
by the Company in Case No. IPC-E-17-13; (2) the Company's proposal for non-export
systems 3 MVA and greater is fair, just, reasonable, and nondiscriminatory; (3) ldaho
Power is well equipped to implement Schedule 68 and provide the necessary
communication and training materials; and (4) any additional reporting requirements
related to customer-owned DERs are appropriately included in the Company's annual Net
Metering Report.
DATED at Boise, ldaho, this 3d day of February 2021.
X*rt.ff"1.+*-*,
LISA D. NORDSTROM
Attorney for ldaho Power Company
]DAHO POWER COMPANY'S REPLY COMMENTS - 8
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 3rd day of February 2021,1 served a true and
correct copy of IDAHO POWER COMPANY'S REPLY COMMENTS on the following
named parties by the method indicated below, and addressed to the following:
Gommission Staff
Edward Jewell
Deputy Attorney General
ldaho Public Utilities Commission
11331 W. Chinden Blvd., Bldg No. 8,
Suite 201-A(83714)
PO Box 83720
Boise, lD 83720-0074
ldaho Conservation League
Benjamin J. Otto
ldaho Conservation League
710 N. 6ft Street
Boise, lD 83702
Idaho Glean Energy Association
Preston N. Carter
Givens Pursley LLP
601 W. Bannock Street
Boise, lD 83702
ldaho Sierra Club
Lisa Young
Mike Heckler
ldaho Sierra Club
503 W Franklin Street
Boise, lD 83702
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kend ra h @q iven sou rslev. co m
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Michael.o [e-mail]
IDAHO POWER COMPANY'S REPLY COMMENTS - 9
ldaho Sierra Glub
Kelsey Jae
Law for Conscious Leadership
920 N. Clover Dr.
Boise, ]D 83703
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Stephanie L. Buckner
Executive Assistant
IDAHO POWER COMPANY'S REPLY COMMENTS - 1O