20210113Comments.pdf

EDWARD J. JEWELL
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-007 4
[phone]
IDAHO BAR NO. 10446
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Street Address for Express Mail:
II33I W CHINDEN BLVD, BLDG 8, SUITE 2OI-A
BOISE, D 83714
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF IDAHO POWER
COMPANY'S APPLICATION TO
ESTABLISH TARIFF SCHEDULE 68 -INTERCONNECTIONS TO CUSTOMER
DISTRIBUTED ENERGY RESOURCES
CASE NO. IPC.E.2O.3O
COMMENTS OF THE
COMMISSION STAFF
The Staff of the Idaho Public Utilities Commission comments as follows on Idaho Power
Company' s Application.
BACKGROUND
On July 20,2020 the Company filed Case No. IPC-E-20-30, requesting permission to
Establish Tariff Schedule 68, Interconnections to Customer Distributed Energy Resources. The
Company states that "The proposed Schedule 68 is intended to comply with Commission Order
Nos. 34046 and34147 from Case No. IPC-E-17-13 which direct the Company to file smart
inverter requirements within 60 days of the final adoption of Institute 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") connecting to the Company's system."
Application at l.
The Company also filed a supplemental application on August 13,2020 that included
changes to Schedules 6, 8, and 84 associated with the Company's proposed Schedule 68.
STAFF COMMENTS JANUARY I3,2O2I
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The Company requests that Schedule 68 become effective 14 days after approval by the
Commission. According to the Company, the 14-day implementation period is necessary to
update its communication materials. Application at 12-13.
STAFF ANALYSIS
Summary
Based on the results of its investigation, Staff supports the Company's proposal. In its
comments, Staff:
a. Supports the Company's proposal to establish a new Tariff Schedule 68,
Interconnections to Customer Distributed Energy Resources, as well as associated
changes to its Schedules 6, 8,72, and 84 tariffs;
b. Supports the proposed Schedule 68 interconnection requirements for all new
exporting Customer-Generators to use a smart inverter; however, Staff also advises
that the proposed interconnection requirements and inverter settings may not
provide all of the functionality stated by the Company in IPC-E-17-13;
c. Supports the proposed Schedule 68 interconnection requirements for non-
exporting systems ("Non-Export Option");
d. Supports the proposed Schedule 68 interconnection requirements for customer-
owned energy storage devices ("Energy Storage Option");
e. Supports the proposed Schedule 68 application and return-trip fees;
f. Supports the modified requirements in the unauthorized systems and expansion
section;and
g. Supports the Company's proposal to eliminate the current triennial recertification
requirement for DERs.
Schedule 68
Staff supports the Company's proposal to create a new interconnection tariff for DERs.
Currently, interconnection requirements for both Public Utility Regulatory Policies Act of 1978
(PURPA) Qualifying Facilities ("QF" or "QFs") and DERs are found in Schedule 72,
Interconnections to Non-Utility Generation. Staff notes that the application process for Schedule
6, 8, and 84 DERs is simpler than the application process for PURPA QFs. For example,
Schedule 72 includes several pages related to the construction, transfer, vested interest, and
STAFF COMMENTS JANUARY I3,2O2I2
operations and maintenance charges related to PURPA QFs that are not relevant to the
interconnection of most DERs.
According to Company witness Aschenbrenner, some DER customers confuse which
sections of Schedul e 72 apply to their applications. Aschenbrenner, Di at 1 3. Staff believes that
creation of a new schedule specifically for DER customers will ameliorate this confusion.
Furthermore, as stated by witness Aschenbrenner, establishing separate interconnection schedules
for PURPA QFs and for DERs will reduce procedural confusion when parties are determining
whether intervention and participation in a case is necessary to protect or advance their interests.
Id.
The Company proposes removing all interconnection requirements related to Schedule 6,
8, and 84 retail customers from ScheduleT2, but it is not proposing any changes to Schedule 72
that would affect PURPA QFs. Application at2.
Most of the provisions and language of Schedule 68 would remain unchanged from the
pertinent sections of Schedule 12 with the following important differences: 1) All new DER
customers interconnecting to the Company's system would be required to use a smart inverter;
2) Schedule 1 (Residential) and Schedule 7 (Small General Service) customer-generators who do
not wish to export their energy would be permitted to interconnect in parallel with the Company's
system so long as they use a non-export control system; 3) Customers with batteries or other
storage devices would be allowed to interconnect with the Company's system so long as the
storage system is coupled with a generator; 4) The proposed schedule includes updated
application, inspection, and return-trip procedures and fees; 5) The proposed schedule allows the
Company to immediately inspect, and if necessary lock, unauthorized systems or expansions; and
6) The proposed schedule eliminates the current triennial inspection, and instead provides for the
Company to inspect any net metering system any time the Company identifies a condition that
presents an unsafe or adverse operating condition.
DERs with a nameplate capacity greater than 3 MVA would be required to follow a
separate process that would include a Feasibility Study, System Impact Study, and Facility Study,
after which the customer would be required to enter into a Customer Generator Interconnection
Agreement prior to connection. The Customer would pay all costs of interconnection under
Rule H and would pay a monthly charge of O.59Vo times the investment in System Protection,
DER Metering, and DER Communication Equipment.
STAFF COMMENTS JANUARY I3,2O2L3
customer-Generator Interconnect Requirements (smart Inverters)
Staff supports the proposed requirement for all new exporting Customer-Generators to use
smart inverters. However, Staff also advises that because the Company does not intend to use the
communications protocols specified by IEEE l54l-2018, smart inverters may not provide all the
functionality stated by the Company in IpC-E-17-13.
In its findings in Final Order No. 34046, the Commission stated, "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." Id. at20.
Although the proposed smart inverter settings would provide voltage control and system
protection, ancillary services such as scheduling, dispatching, load balancing, and forecasting are
not possible without real-time or near real-time communications protocols. The Company
proposes that for systems smaller than 3MVA, smart inverters be programmed so that they
operate autonomously, and that IEEE 1547-2018 communications protocols not be enabled.
Company Production Response to Staff Production Request No. 27. The Company only plans to
implement communications protocols for DER systems that are 3 MVA or larger.
In the event that the Company were to implement protocols to enable communication with
all DERs, the Company would likely require each smart inverter to be connected to the internet.
Id. Each inverter would also need to be manually reprogrammed to enable communications
protocols.
Reactive power
The reactive power settings specified by the Company will allow the inverter to control
voltage and either supply or consume reactive power with little or no impact on either the power
consumed on-site by the customer or exported to the Company's system. The Company proposes
that smart inverters be set for IEEE 1547-2018 performance Category B with reactive power
mode set to voltage-Reactive power. Application Attachment 1, Table 1.
Staff explains that electric motors and certain other electrical devices can induce a
mismatch between the phase angle of the alternating current and the alternating voltage of an AC
power system. The effect of this mismatch extends far beyond the vicinity of the electromagnetic
device causing the mismatch, and results in power that is unusable even though it is still present
in the power grid. Electrical motors and similar devices are said to consume, or absorb, reactive
power.
STAFF COMMENTS JANUARY I3,2O2I4
Spinning generation resources that produce alternating current can produce a phase angle
mismatch that is opposite that produced by electrical motors, and thus spinning resources can
counter the effects of electrical motors. Spinning generation resources are said to produce, or
inject, reactive power. Absent a source of reactive power, a power grid can become unstable even
though there is sufficient real power on the grid. Production of reactive power is an important
ancillary service provided by hydro and thermal generation resources.
Direct current generators such as photo-voltaic cells and some wind turbine generators
produce no reactive power, even when their output is converted to Alternating Current by a
conventional inverter. Given that the preponderance of DERs derive their power from photo-
voltaic cells, there is a justifiable concern that the grid could be destabilizedby a sufficiently high
density of DERs. IEEE 1547 -2018 addresses this concern by requiring that DERs be able to both
produce and consume reactive power. The Company's proposed inverter settings ensure that
DERs are consuming sufficient reactive power for normal grid operations, even when DER
penetration levels are relatively high.
IEEE 1547-2018 provides two different performance categories: A and B. Category B is
more stringent than Category A, and requires the DER to be able to either absorb or inject more
reactive power than Category A. Category B settings are intended to provide enough reactive
power control to maintain grid stability, even when DER penetration is relatively high.
The Company proposes to use voltage deadband settings that differ slightly from those
recommended in IEEE 1547-2018. The Company explains that this change is intended to align
smart inverter parameters with the parameters used by the Company's existing infrastructure.
Otherwise, the Company's proposed settings conform with IEEE 1541-2018 recommendations.
Staff believes the Company's proposed modification of IEEE standards are reasonable.
The Company's proposal to require smart inverter default settings to be set for normal
operating performance Category B has an additional benefit: By selectively producing or
consuming reactive power, a smart inverter will be able to provide limited local voltage control.
So long as a DER's smart inverter is properly sized to meet both its real and reactive power needs,
the Company's proposed settings will allow the DER to provide voltage control without curtailing
the quality or quantity of power available to the customer for use on-site or for export.
STAI]F COMMENTS JANUARY L3,2O2I5
Ride - throu gh and anti - is landin g
Prior to the 2018 revision of IEEE 1547 , inverters used by DERs were designed to shut off
the DER within a few seconds of detecting an abnormal voltage fluctuation. It was recognized
that with increasing DER penetration, it is possible for the voltage fluctuation caused by the
shutdown of one DER to cause other DERs to shut down, resulting in a cascade of DERs being
removed from service. This, in turn, could destabilize large portions of the grid. IEEE 1547-
2018 addresses this problem by requiring DERs to respond to abnormal voltage fluctuations in a
more nuanced way than simply shutting down. IEEE 1547-2018 requires DERs to respond
proportionately to a wide range of abnormal operating conditions prior to shutting down. This is
referred to as ride-through.
The Company proposes that smart inverters be set to use IEEE 1547-20L8 Category III
Voltage Ride-Through settings. These settings conform with industry best practice for DER
systems operating without a communication interface that would allow the Company to detect and
coordinate the responses of smart inverters to abnormal voltage deviations. Staff notes that
settings similar to those proposed by the Company are currently in use in California. IEEE 1547-
2018 at 101, and Rule 21 Tariffs for Pacific Gas and Electric, Southern California Edison, and
San Diego Gas and Electric. Staff agrees with the Company's proposed ride-through settings.
Grid-tied inverters use power provided by the grid for frequency and voltage control. In
the event that power from the grid is intemrpted for more than a few seconds, a grid-tied inverter
will shut down. This mode of operation is a safety feature, since it assures that grid-tied systems
can't be energized when power lines are shut down for maintenance.
Given a sufficiently high density of DERs without proper anti-islanding protocols, it is
possible for DERs to continue to energize the grid even after grid power is interrupted. Without
the grid power as a reference, voltage and frequency can change rapidly. This condition, called
islanding, can preclude maintenance work in affected areas until Company staff can manually
shut-down each DER.
The Company proposes using IEEE 1547-2018 protocols, which require that DERs use
anti-islanding protocols based on the rapid frequency swings that are characteristic of islanding
events. Staff agrees with the Company's anti-islanding proposal.
STAI]F COMMENTS JANUARY I3,2O2I6
Existing systems
The Company proposes that new DERs be required to use smart inverters, and does not
propose that existing, functional inverters be replaced. The Company proposes that as inverters
break-down and need to be replaced, they be replaced with smart inverters. Staff concurs with
this proposal. Currently, no portion of Idaho power's grid has a sufficiently high DER density to
cause instability related to a deficiency of reactive power, and there have been no reports of
islanding. Furthermore, Staff was unable to determine that smart inverters provide any
quantifiable system-wide benefit when DER penetration rates are low. Staff believes that
requiring existing customers to retrofit their systems with smart inverters would impose a costly
and unnecessary expense.
Implementation and market availability
The Company plans to use Underwriters Laboratories ("UL") certification as the criteria
for determining whether or not to approve a particular smart inverter (UL 1741 SB).
Unfortunately, the UL has not yet issued a finaI, comprehensive list of approved inverters. In the
interim, the Company plans to use a supplemental list, UL 174I SA, to make its determination.
Inverters not on UL l74l SA will be vetted by the Company on a case-by-case basis. Company
Production Response to Staff Production Request No. 5.
Through conversations with solar installers and industry representatives, Staff learned that
sufficient quantities of UL 1741 SA compliant smart inverters are available to meet foreseeable
demand.
Non-export option
In Case No. IPC-E-I7-13, Vote Solar filed a Petition for Reconsideration of Order
No. 34046 in which they asked the Commission to require the Company to revise the new
Schedules 6 and 8 so that they apply only to customers who export electricity. In the Final Order
on Reconsideration, the Commission ordered, "Consequently, alongside the parameters set forth
in Order No. 34046, a non-export option should be studied for feasibility and vetted for safety and
operational concerns by the Company and interested stakeholders in the forthcoming docket."
Order No. 34147.
STAFF COMMENTS JANUARY I3,2O2I7
As discussed in Aschenbrenner's direct testimony, the Company subsequently filed docket
No. IPC-E-18-15 which considered, among other things, interconnection requirements for non-
exporting systems. Aschenbrenner, Di. at l0-I2.
In the present case, the Company proposes that Schedule 1 and 7 Customer-Generators
who do not export energy be permitted to remain on Schedules 1 and 7 so long as the total
nameplate capacity of the DER is 25 kVA or less, and the DER uses a non-export control system.
The Company proposes that customers use one of three export control systems: 1)
Advanced functionality, 2) Reverse power protection, or 3) Minimum power protection. The
Company also proposes that all inverter-based DERs use option 1, advanced functionality, since
the necessary functionality is already built into IEEE 1547-2018 compliant smart inverters.
The second and third options allow non-inverter based systems, such as run-of-river
generators or generators using biomass, to interconnect with the Company's grid.
Schedule 68 defines unauthorized inadvertent export as export exceeding three hours of
DER total nameplate capacity in any 30-day period. In the event of an unauthorized inadvertent
export, the customer would be required to rectify the problem within 30 days of notification by
the Company.
Staff believes that the Company's proposed Schedule 68 non-export option is reasonable,
that it adequately protects the Company's system, and that it provides Customer-Generators a low-
cost way to generate their own power while remaining on Schedules I and 7.
Energv storage option
Although not specifically ordered by the Commission, the proposed Schedule 68 also
includes a mechanism for allowing DER customers using batteries and other storage devices to
interconnect with the system. Under the Company's proposal, storage facilities must be coupled
with a Schedule 6, 8, or 84 generator in order to export energy to Idaho Power's system.
Energy storage devices may either share an inverter with a generation facility ("DC
Coupled") or use a separate stand-alone inverter ("AC Coupled"). Staff anticipates that most
Customer-Generators using photo-voltaic and other inverter-based generation systems will opt to
use a DC Coupled system; however, it is likely that Customer-Generators using run-of-river and
biomass systems will use an AC Coupled configuration. Staff believes that both the DC Coupled
and AC Coupled configurations will provide DER customers a means for storing the energy they
produce while protecting the grid.
STAFF COMMENTS JANUARY I3,2O2I8
Annlication and return-trio fees
Staff recommends that the Commission approve the application fee and return trip charge
proposed in Tariff Schedule 68.
The Company proposes that customers submit a $100.00 application fee with their
completed application to interconnect their DER with the Company's system. Application at
Attachment l, Sheet 68-10. The Company explained that the $100.00 application fee was first
approved as part of IPC-E- 12-27 . Aschenbrenner, Di. at 7. Using production requests and
workpapers provided by the Company, Staff reviewed the $100.00 application fee, and concludes
that it is reasonable.
As part of the application process, the Company will conduct an on-site inspection. In the
event that the system does not pass its first inspection, customers will be charged an additional
$61.00 fee for each trip needed to verify that the system conforms to the requirements of Schedule
68. Application at Attachment 1, Sheet 68-12. Staff reviewed Company workpapers and
calculations and determined that the $61.00 charge is reasonable.
Unauthorized installations and expansions
Staff recommends that the Commission approve the modifications dealing with
unauthorized installations and expansions that are proposed in Schedule 6g.
Currently, under Schedule 72, unauthorized installations and expansions are subject to
immediate Company inspection and disconnection without prior notice. If proper disconnection
equipment is present, the Company will open the disconnect, lock the customer out of their
system, and then notify the customer within 24 hours. If the proper disconnect equipment is not
present, customers are required to disconnect their DER from the Company's system immediately
by any means available. According to the Company, the proper disconnection equipment is
usually present. Aschenbrenner, Di. at2I-22.
The Company proposes eliminating the current Schedule 7? requirement to lock the
customer out of their system. Instead, the Company would rely on the Customer-Generator to
remain disconnected while they either complete the full Customer Generator Interconnection
process, or they permanently disable their DER's connection with the Company's system.
According to Company witness Aschenbrenner, the requirement to lock a system can
require an Idaho Power employee to return to the DER to unlock the system any time the
customer, installer, or state inspector is trying to bring the system into compliance. The Company
STAFF COMMENTS 9 JANUARY 13,2021
believes it reasonable to rely on the Customer-Generator or installer to keep the system
disconnected, just as it does for new systems that are installed and awaiting inspection.
Aschenbrenner, Di at 23.
Customer-Generators would be given 12 months to bring their systems into conformance
with the Company's Schedule 68 interconnection requirements.
STAFF RECOMMENDATIONS
Staff recommends that the Commission allow the company to establish proposed Tariff
Schedule 68, Interconnections to Customer Distributed Energy Resources.
Respecttully submitted this lSth day of January 2021.
t (
Edward J
Deputy
Technical Staff: Mike Morrison
Travis Culbertson
Rachelle Farnsworth
i : umisc/commentVipce2O. 30ejmmtncrf comments
STAFF COMMENTS l0 JANUARY I3,2O2I
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 13th DAY OF JANUARY 2021,
SERVED THE FOREGOING COMMENTS OF THE COMMISSION STAFF, IN
CASE NO. IPC-E-20-30, BY E-MAILING A COPY THEREOF, TO THE FOLLOWING:
LISA D NORDSTROM
REGULATORY DOCKETS
IDAHO POWER COMPANY
PO BOX 70
BOrSE rD 83707-0070
E-MAIL: [e-mail]
dockets @ idahopower.com
BENJAMIN J OTTO
ID CONSERVATION LEAGUE
710 N 6TH STREET
BOISE D 83702
E-MAIL: [e-mail]
LISA YOUNG
MIKE HECKLER
IDAHO SIERRA CLUB
503 W FRANKLINE ST
BOISE D 83702
E-MAIL: lisa.vouns@ sierraclub.org
michael.p.heckler @ gmail.com
CONNIE G ASCHENBRENNER
TMOTHY E TATUM
IDAHO POWER COMPANY
PO BOX 70
BOrSE rD 83707-0070
E-MAIL: [e-mail]
ttatum @ idahopower.com
PRESTON N CARTER
GTVENS PURSLEY LLP
601 W BANNOCK ST
BOISE ID 83702
E-MAIL: prestoncarter@ givenspurslev.com
kendrah @ gi venspursley.com
KELSEY JAE
LAW FOR CONSCIOUS LEADERSHIP
920 N CLOVER DR
BOISE ID 83709
E-MAIL: [e-mail]
ARY
CERTIFICATE OF SERVICE