20070530Compliance filing re Commitment 40.pdf

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May 30, 2007 'i"
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Idaho Public Utilities Commission
472 West Washington
Boise, ID 83702
Attn: Jean Jewell
Commission Secretary
RE:Compliance Filing Pursuant to Commitment 40 of Stipulation Appendix A, Consolidated
List of Commitments, Docket No. P AC-05-
Dear Ms. Jewell:
MidAmerican Energy Holdings Company ("MEHC") and PacifiCorp submit to the Idaho Public
Utilities Commission ("Commission ) an original and seven (7) copies ofPacifiCorp
Renewable Energy Action Plan. Copies of the report are available electronically and will also be
posted on PacifiCorp s web site, at www.pacificorp.com.
The Renewable Energy Action Plan is provided in compliance with General Commitment 40
pursuant to the Commission Order granting approval of the acquisition ofPacifiCorp by
MidAmerican Energy Holdings Company, issued March 14 2006, in the referenced proceeding.
The Commission approved the acquisition ofPacifiCorp by MEHC, subject to a Consolidated
List of Commitments specified in a settlement agreement supported by all parties to the
proceeding. Included in this consolidated list is MEHe's and PacifiCorp s commitment
regarding the filing of the enclosed report. The general commitment in pertinent part is as
follows:
40) .. .MEHC and PacifiCorp commit to work constructively with states to implement
renewable energy action plans so as to enable PacifiCorp to achieve at least 1400 MW of
cost-effective renewable energy resources by 2015. Such renewable energy resources are
not limited to wind energy resources.
By copy of this letter, other parties to the proceeding are being provided notice of this filing.
It is respectfully requested that all formal correspondence and Staff requests regarding this filing
be address to the following:
Bye-mail (preferred):datareq uest~pac ifi corp. com
By Fax:[phone]
By regular mail:Data Request Response Center
PacifiCorp
825 NE Multnomah, Suite 2000
Portland, OR 97232
If there are informal inquiries concerning the filing, please contact Brian Dickman, Idaho
Regulatory Affairs Manager, at [phone].
Sincerely,
~r" ~f.A
Jeffrey K. Larsen
Vice President, Regulation
Enclosure
cc: Service List P AC-05-(wi out enclosures)
:'
CERTIFICATE OF SERVICE
I hereby c~ftify that on this 30th day of May, 2007, I caused to be served, via E-mail, if
address a~Hable or U.S. Mail a true and correct copy of the Cover Letter regarding the
Renewable Energy Action Plan in PAC-05-08 to the following:
Andrea L. Kelley
Vice President, Regulation
ACIFICORP
825 NE Multnomah, Suite 2000
Portland, OR 97232
Mail: andrea.kelly(illpacificorp.com
Douglas L. Anderson
Senior Vice President & General
Counsel
MidAmerican Energy Holdings
Company
302 S. 36th Street, Suite 400
Omaha, NE 68131
Mail: danderson(illmidamerican.com
Eric L. Olsen
Racine, Olson, Nye, Budge & Bailey,
Chartered
201 E. Center
O. Box 1391
Pocatello, ID 83204-1391
Mail: elo(illracinelaw.net
Barton L. Kline, Senior Attorney
Monica B. Moen, Attorney II
Idaho Power Company
O. Box 70
Boise, ID 83707
Mail: bkline~idahopower.com
mmoen(illidahopower.com
Brad M. Purdy
Attorney at Law
2019 N. 17th Street
Boise, ID 83702
Mail: bmpurdv(illhotmail.com
R. Scott Pasley
Assistant General Counsel
R. Simplot Company
O. Box 27
Boise, ID 83702
Mail: spaslev(illsimplotcom
Mark C. Moench
Senior Vice President - Law
MidAmerican Energy Holdings Company
201 S. Main, Suite 2300
Salt Lake City, UT 84111
Mail: mcmoench(illmidamerican.com
Anthony Yankel
29814 Lake Road
Bay Village, OH 44140
Mail: tony(illyankel.net
John R. Gale
Vice President, Regulatory Affairs
Idaho Power Company
O. Box 70
Boise, ID 83707
Mail: rgale(illidahopower.com
Arthur F. Sandack, Esq.
8 E. Broadway, Suite 510
Salt Lake City, UT 84111
Mail: asandack(illitower.net
Donald L. Howell, II
Deputy Attorney General
Idaho Public Utilities Commission
472 W. Washington (83702)
O. Box 83720
Boise, ID 83720-0074
Mail: donlhowell(illpuc.idaho.gov
Terri Carlock
Accounting Supervisor
Idaho Public Utilities Commission
472 W. Washington
O. Box 83720
Boise, ID 83720-0074
Mail: terri.carlock(illpuc.idaho.gov
Randall C. Budge
Racine, Olson, Nye, Budge & Bailey,
Chartered
201 E. Center
O. Box 1391
Pocatello, ID 83204-1391
Mail: rcb(illracinelaw.net
Katie Iverson
Brubaker & Associates
17244 W. Cordova Court
Surprise, AZ 85387
Mail: kiverson consultbai.com
David Hawk
Director, Energy Natural Resources
R. Simplot Company
O. Box 27
I Boise
, ID 83702
Mail: dhawk sim lot.com
James R. Smith
Monsanto Company
Highway 34 North
O. Box 816
Soda Springs, ID 83726
Mail: lim.r.smith(illmonsanto.com
Alan Herzfeld
Herzfeld & Piotrowski LLP
713 W. Franklin
O. Box 2864
Boise, ID 83701
Mail: aherzfeld(ill net
R. Scott Pasley
Assistant General Counsel
R. Simplot Company
O. Box 27
Boise, ID 83702
Mail: s aslev(illsim lot.com
Debbie DePetris
Regulatory Analyst
~ E~!;N ~QN~ P
Renewable Energy Action Plan
May 30, 2007
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Background
MidAmerican Energy Holdings Company ("MEHC") made a commitment to work with the
states to produce a Renewable Energy Action Plan ("the Renewable Plan ) as part of its
acquisition of PacifiCorp. PacifiCorp committed to filing a ten-year plan, concurrent with its
next Integrated Resource Plan ("IRP") filing to acquire 1 400 megawatts of new cost-effective
renewable resources by 2015, including specific milestones over a ten year planning period as to
when resources will be added. The Renewable Plan also includes a ten-year plan for installing
transmission that will facilitate the delivery of renewable energy and the achievement of
PacifiCorp s goal of acquiring at least 1 400 megawatts of cost-effective renewable resources by
2015. Consistent with the commitments, MEHC and PacifiCorp filed a preliminary plan for
achieving the 1 400 megawatt renewable target on September 21 , 2006. This document is an
updated Renewable Energy Action Plan and is being filed concurrent with PacifiCorp s 2007
Integrated Resource Plan in May 2007.
Overview
PacifiCorp s 2003 Integrated Resource Plan found that 1 400 megawatts of renewable resources
using generic wind projects as a proxy, formed part of the least cost portfolio of resources. This
was reaffirmed in the 2004 IRP and the 2004 IRP Update (both filed in 2005) and was
subsequently adopted by MEHC as part of the transaction commitments. This plan reviews
progress toward the goal of acquiring 1 400 megawatts of renewable resources by 2015 , and sets
forth the Renewable Plan objectives and action items outlined to meet the MEHC commitment.
The 2007 IRP filed concurrent with this filing raises the bar, selecting 2 000 megawatts of
renewable resources targeted by the end of 2013.
This Renewable Plan defines what PacifiCorp intends to consider as renewable resources in
meeting the objective identifies renewable resource acquisitions to date and broadly
characterizes activities currently underway (without revealing confidential commercially
sensitive information). The Renewable Plan is divided into four categories: Resource
Acquisition, Institutional, System Operations and Transmission. These components were
designed to provide a foundation for the acquisition of cost-effective renewable resources by the
target date. Finally, a summary is provided with a table showing the components of the plan
together.
Renewable Resources Definition for meeting the 1,400 Megawatt Target
For the purposes of this document, PacifiCorp adopts a definition of renewable resources as
follows:
wind;
waste;
1 Note
, "
waste" is included within the current Oregon definition of "renewable energy resources" (Le., Oregon
restructuring legislation, Senate Bill 1149 (1999), see
http://www.leg.state.or.us/99reg/measures/sbll00.dir/sbl149.en.html). However the broad eligibility of "waste
solar photovoltaic or solar thermal energy;
geothermal;
biomass and biomass by products, excluding municipal solid waste or wood pieces
that have been treated with chemical preservatives such as creosote
pentachlorophenol or copper chrome arsenic, which include:
(a) organic human or animal waste;
(b) spent pulping liquor;
(c) forest or rangeland woody debris from harvesting or thinning conducted
improve forest or rangeland ecological health and to reduce uncharacteristic
stand replacing wildfire risk;
(d) wood material from hardwood timber grown on private, managed, or
timberlands;
(e) agricultural residues;
(j) dedicated energy crops; and
(g) biogas produced from organic matter, wastewater, anaerobic digesters or
municipal solid waste.
certified low impact hydroelectric or upgrades to existing hydroelectric facilities
where the additional generation does not result in new water diversions or
impoundments;
wave, tidal, or ocean thermal energy; or
hydrogen derived from photovoltaic electrolysis or a non-hydrocarbon derivation
process.
For the purposes of meeting the 1 400 megawatt target, PacifiCorp will utilize the nameplate
generating capability of any renewable resource added to PacifiCorp s portfolio beginning in
January 2003 (the date that PacifiCorp first committed to acquiring 1 400 megawatts of cost-
effective renewable resources). These renewable resource additions will include all renewable
resources as defined by the Renewable Resource definition. Purchases from Qualifying Facilities
QFs ) under the Public Utility Regulatory Policies Act of 1978 ("PURP A") will count towards
satisfaction of the capacity goal whether or not PacifiCorp is able to secure the renewable energy
credits ("RECs ) associated with the QF production (refer to the QF discussion later in this
Plan).
Renewable Resource Acquisitions and Current Activities
Table 1 , below, shows a snapshot of the renewable resource capacity additions since January 1
2003 that are either in service or have been committed to by the company as well as planned
acquisitions through 2015. With the Marengo and Goodnoe Hills wind farms (currently under
construction) in PacifiCorp s portfolio, PacifiCorp has met, and exceeded, its commitment to
have 400 megawatts of new cost-effective renewable resources in its generation portfolio by
December 31 2007. PacifiCorp will need to acquire approximately 750 megawatts of additional
cost-effective renewable resources to meet the 1 400 megawatt target by 2015. Of that total, over
projects is likely to be rescinded with the passage of an Oregon Senate Bill 838 (2007). PacifiCorp reserves the right
to consider waste projects since it was an eligible renewable resource at the time the original 1 400 megawatt
commitment was made.
500 additional megawatts are actively being pursued for addition to PacifiCorp s generation
portfolio during 2008.
Table 1
Renewable Resource Acquisitions
(Nameplate MW)
Projects Agreements 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015
H dro Upl!:rades
Lemolo #1
JC Bovle #1
JC Bovle #2
Rockv Reach
Swift II Upgrade
Swift 12Uegrade
Swift 13 Upgrade
BiomasslBiol!:as
PPAI
Douglas County Forest Products
RickReal Dairv
DeRuvter Dairv
DrvCreek Landfill
Evergreen Biooower (Freres)
Rough and Ready Lumber
PPA2
PPA3
Geothermal
Blundell Uegrade
ICove Fort 201 201 201 201 201 201 201
Wind
Combine Hills PPA
Wolverine Creek
Leaning Junieer 101 101 101 101 101 101 101 101 101 101
Pioneer Ridge
Spanish Fork Wind Park
Mountain Wind I
Mountain Wind II
Schwendiman Fanns
Under Construction
Marengo 1401 1401 1401 1401 1401 1401 1401 1401 140
Goodnoe Hills 941 941 941 941 941 941
Under development and/or negotiations
Alan Barklely I (Wasco)IC F
Alan Barkley 2 (The Dalles)leF
Wind Project Ongoing Negotiations 4 358 358 358 358 358 358 358 358
Proxy Resources (Unspecified)
IRP Wind 2009 100 100 100 100 100 100 100
IRP Wind 2010 300 300 300 300 300 300
IRP Wind 2011 200 200 200 200 200
IRP Wind 2012 100 100 100 100
IRP Wind 2013 300 300 300
Total Renewable Additions 260 671 192 292 592 817 922 247 247 247
2 PacifiCorp is continuing to evaluate the economics of further expansion of the Blundell facility
The table above includes several upgrades to existing hydroelectric facilities. These hydro
upgrades provide capacity and energy without change to impoundments or existing stream flow
regimes. Additional upgrades are under consideration but are not specified at this time.
Consistent with the 2007 IRP, PacifiCorp plans to continue to pursue additional renewable
resources at an average rate of 200 megawatts per year through 2013 , meeting the 1 400
megawatt commitment in 2010, well ahead of schedule. These are represented in the table above
as proxy wind resources but will be selected from any available cost-effective renewable
resources that meet the definition herein. In addition, PacifiCorp points out that the mix of
renewable resources projected to be acquired beyond 2007 is today s projection. Future
projections will be updated to account for changes in public policy, regulatory requirements, and
technology advancements.
State Renewable Portfolio Standards (RPS)
A renewable portfolio standard (RPS) is a policy that obligates each retail seller of electricity to
include in its resource portfolio (the resources procured by the retail seller to supply its retail
customers) a certain amount of electricity from renewable energy resources, such as wind and
solar energy. The retailer can satisfy this obligation by either (1) owning a renewable energy
facility and producing its own power, or (2) purchasing renewable electricity from someone
else s facility. Some RPS statutes or rules allow retailers to trade their obligation as a way of
facilitating compliance with the RPS by avoiding the need to secure scarce or costly transmission
service. Under this trading approach, the retailer, rather than maintaining renewable energy in its
own energy portfolio, instead purchases tradable renewable energy credits ("RECs ) that
demonstrate that someone else has generated the required amount of renewable energy.
RPS policies are currently implemented at the state level, and vary considerably in their
requirements with respect to time frame, resource eligibility, and treatment of existing plants
arrangements for enforcement and penalties, and whether they allow trading of RECs.3 As of
mid-2007, 23 states and the District of Columbia had adopted RPS regulations. The most recent
adoption occurred in Washington, which passed a ballot measure in November 2006. Two states
in PacifiCorp s service territory-California4 and Washington-now have an RPS in place.
Oregon is considering such a standard during the current 2007 legislative session.
Congress is expected to take up federal energy policy legislation, including the possibility of a
federal RPS, as early as summer 2007. On the House side, Rep. Tom Udall (D-) has
introduced legislation creating a 20 percent standard by 2020. Senate Energy and Natural
Resources Committee Chairman Jeff Bingaman (D-) has indicated he is planning legislation
with a level of 15 percent by 2020.
3 See, http://www.eere.energy.gov/states/maps/renewable ..,portfolio - states.cfm4 California rulemaking, currently in progress, would strengthen the existing RPS, requiring a retail seller to increase
its total procurement of eligible renewable resources to at least 33 percent of its retail sales no later than Dec. 31
2020. Reference: Senate Bill 411 (2007)
The table below identifies each state s current or expected RPS procurement targets, expressed
as a percentage of retail sales, as well as a federal RPS proposal currently being circulated by
Senator Bingaman (D-
Table 2
PrOi osed
Year California Wasbin2ton Ore2on Federal
2007 17%
2008 18%
2009 19%
2010 20%75%
2011 20%75%
2012 20%75%
2013 20%7.50%
2014 20%50%
2015 20%15%7.50%
2016 20%15%50%
2017 20%15%11.25%
2018 20%15%11.25%
2019 20%15%11.25%
2020 33%15%20%15%
2021 33%15%20%15%
2022 33%15%20%15%
2023 33%15%20%15%
2024 33%15%20%15%
2025 33%15%25%15%
The remainder of this paper provides a description and status of the additional activities
PacifiCorp is undertaking to ensure acquisition of sufficient resource and transmission capability
to meet the 1 400 megawatt renewable resource objective.
Action Items
Resource Acquisition Action Items
The primary objective of the Renewable Energy Action Plan is to acquire the remaining
renewable resources shown in Table 1 , above, to achieve the 1 400 megawatt commitment by the
2015 target date. These additional renewable resources must be cost-effective and provide
sufficient capability to PacifiCorp s renewable generation portfolio to ensure compliance with
the mandatory RPS targets through the Plan s current time horizon; e., by 2015. In order to
secure cost-effective resources, the year by year acquisitions may vary from the schedule shown
5 Actual compliance obligations are likely to be achieved using eligible renewable resources, renewable energy
credits, or a combination of the two.
in Table 1. Issues that may affect attaining a systematic and constant rate of cost-effective
acquisition are the unpredictable nature of the federal production tax credit (PTC), state-specific
renewable portfolio standards, transmission limitations, carbon regulations, capital costs, and
market prices.
Although the PTC has consistently been extended since its inception, the extension has not
always happened prior to the end of the previous term. This has caused major boom and bust
cycles as the industry waits for Congressional action on extending the PTC. In one of its last
actions of 2006 Congress extended the PTC at current levels, adjusted for inflation, through the
end of 2008 . However, there is no certainty that it will continue past this date or, if it does, how
long it will be extended or that it will be renewed at current levels.7 As long as acquisition of
additional renewable resources remains cost-effective, PacifiCorp plans to continue to acquire
such resources
Action Item: Continue to negotiate for the acquisition of cost-effective renewable
resources until such time as the 1 400 megawatt goal is achieved.
Action Status: Multiple resources are currently being pursued and transmission service
for specific resources has been requested. Congress has extended the PTC
through the end of 2008, improving the outlook for the systematic
development of renewable resources. The Company continues to support
multi-year extensions of the PTC to provide stability to the industry.
PacifiCorp maintains ownership of properties throughout its system. Given the proximity of
some of these holdings to transmission facilities, the company proposes to engage in an
assessment of wind resources on the existing properties that may have the potential for cost-
effective resource development.
Action Item: Perform a wind resource inventory and assessment on PacifiCorp property
holdings by June 30, 2007.
Action Status: The proposed inventory is currently underway and on schedule.
Renewable resources can face important impediments relating to the high voltage transmission.
system. Many potential renewable resources are located far from population centers where the
power must ultimately be delivered. In addition, transmission lines are constructed to transfer the
maximum capability of a power plant and wind projects usually have relatively low capacity
6 Tax Relief and Health Care Act of 2006 (H.R. 6408)7 PacifiCorp s parent, MidAmerican Energy Holdings Company, is actively lobbying Congress for a long-term
extension of the FTC.8 Consistent with the IRP PacifiCorp expects to continue pursuing renewable opportunities beyond the 1 400
megawatt commitment as long as cost effective resources are available.
factors, often generating about a third of the maximum capability on average. This can have the
effect of tripling the cost of transmission service on a dollar-per-megawatt-hour basis. Another
issue is that long distance transmission line construction may have more transfer capability than
an individual project requires. This means that individual power project proposals often cannot
absorb the costs of a full transmission construction project. Finally, the time required to site
permit, design, and construct new transmission lines often does not align with the time frame for
development of new wind sites. Transmission can require five or more years, whereas permitted
and fully developed wind generation sites can be constructed upon in less than a year.
PacifiCorp can help facilitate developing new areas for renewable resource development that are
currently constrained by transmission transfer capability. This can be done through PacifiCorp
Integrated Resource Plan in which competing regions are evaluated against one another
including the cost of transmission and the relative value of power from renewable resources in
the regions due to projected capacity factors and timing of generation (e., winter/summer
day/night). Once the most economic regions are determined, PacifiCorp can evaluate project
proposals in those regions in combination with existing or possible future transmission facilities.
Action Item: Identify likely regions for new renewable resource development through
the IRP and evaluate potential resources within those regions.
Action Status: The 2007 IRP identifies various potential wind projects located in specific
locations throughout the Northwest and Western United States. These
proxy resources were developed from PacifiCorp experience with wind
developers and from responses to the 2003 renewable resource request for
proposals.
As part of its renewable acquisition plan, PacifiCorp intends to conduct an economic assessment
of biomass project opportunities, focusing on the Oregon biomass market segments. The main
biomass market segments are wood mill waste and forest waste resulting from timber residue and
forest thinning in the Pacific Northwest. The initial focus on Oregon biomass opportunities is a
result of: 1) the greater number of economic incentives available in Oregon than other
surrounding states and 2) the greater quantity of biomass generation that exists or is planned in
Oregon than other surrounding states. Additional opportunities in the areas of sewage treatment
plant digesters, dairy-based anaerobic digesters, and landfill gas to energy will be pursued as
they are identified.
Action Item: Perform an economic assessment of biomass project opportunities
focusing on the Oregon biomass market segment.
Action Status: PacifiCorp has completed an overall biomass strategy and is in the process
of implementing the biomass strategy. PacifiCorp has signed Purchase
Power Agreements with multiple biomass/biogas projects and expects to
have at least 66 megawatts on line by the end of 2008, as shown in Table
1. Negotiations for additional development continue.
Institutional Action Items
PacifiCorp recognizes that a successful renewable resource acquisition plan necessitates active
measures to lay a framework for continued progress. PacifiCorp s ability to meet the 1 400
megawatt target has been enhanced by the MEHC acquisition by MEHC's commitment to
include an own/operate alternative in any commission-approved request for proposals for
resources with a dependable life greater than ten years and greater than 100 megawatts.
Action Item: Evaluate staffing needs with regard to renewable resource acquisition
project management, and/or development by March 1 2007.
Action Status: PacifiCorp has evaluated staffing needs with respect to new resource
acquisition, re-allocated personnel to support the increased activity, and is
currently evaluating the staffing need to support the future operational
needs of recently acquired resources.
As described previously, the uncertainty around the PTC extension impacts the renewable
resource market by disrupting the systematic addition of new renewable resources through time.
It also exacerbates the timing issues related to combining wind resources with the needed
transmission expansions. It is incumbent on PacifiCorp to maintain a political presence in
support of efforts to reduce the uncertainty surrounding renewal of PTC legislation.
Action Item:Support efforts by renewable resource advocacy groups to reduce
uncertainty in PTC extension and directly contact influential individuals to
express PacifiCorp s support of certainty in the federal renewable resource
production tax credit.
Action Status: Congress has extended the PTC through the end of 2008. The Company
continues to support efforts by renewable resource advocacy groups to
enable multi-year extensions of the PTC to provide stability to the
industry .
An important mechanism for PacifiCorp s acquisition of renewable resources is through the
acquisition of qualifying facilities (QFs) under the Public Utility Regulatory Policies Act
(PURP A) of 1978. Under PURP A, utilities must purchase power from QFs at their avoided
costs. The avoided cost methodologies are set by the various states, and the Federal Energy
Regulatory Commission has deferred to the states the issue of whether the QF, or the purchasing
utility, owns the RECs under QF contracts. Some states have granted ownership of RECs to the
utilities, other states have granted ownership to the QF seller, and still others have not yet
addressed the ownership issue at all. PacifiCorp s service territory encompasses states in all three
of those conditions.
As part of the contracting process, PacifiCorp will make a good faith effort to secure the RECs
associated with a QF. However, those credits are a function of production (i.e., kilowatt-hour
output); while PacifiCorp s commitment is a function of capacity (i.e., megawatts). Thus, if the
QF otherwise satisfies the definition of a renewable resource, the QF capacity will count towards
the satisfaction of the 1 400 megawatt commitment even if PacifiCorp is unsuccessful in
securing the RECs.9 Table 3 , below, summarizes, by state, the current Commission treatment of
REC ownership as it relates to QF contracts.
Table 3
California Idaho Oregon Utah Washington Wyominj!
For new
CommIssion contracts, the PacifiCorp
Renewable will decide QF owns but PacifiCorp owns the RECs
Energy PacifiCorp is for the term of
Certificates No decision when the QF allowed to owns but QF No decision the power
position contract is purchase can buy back purchasefiled.
RECs if not agreement
over market
Action Item: Work with state regulators to clarify REC ownership for PURPA QF
contracts and applicability toward Federal and/or state-specific RPS
standards.
Action Status: PacifiCorp has been an active participant in each of its jurisdictions as the
states works through the issues. Recent activity includes the treatment of
RECs generated by QFs within the proposed Oregon RPS legislation
Senate Bill 838.
In the Washington Utilities and Transportation Commission RPS
rulemaking, PacifiCorp filed commentslO which include a clarifying
question regarding the definition of "renewable energy certificate" and
ownership rights of "non-power attributes.
9 PacifiCorp acknowledges that for the purpose of certain regulatory reporting and customer disclosure provisions, it
may not be able to identify the production of such QF resources as renewable ifPacifiCorp does not own the RECs.
The absence of REC ownership, however, does not change the underlying fact that the generation capacity in
PacifiCorp s portfolio is powered by a renewable "fuel."10 PacifiCorp s comments may be downloaded from http://www.wutc.wa.gov/rms2.nsf/
frm2005V w DS W eb?OpenF orm&vw2005L 1 DktSh=061895- Documents&NA V999999.
Operational Action Items
Continuous concern has been expressed regarding operational issues surrounding the relatively
volatile and less-predictable nature of some renewable resources. Considerable progress has been
made at PacifiCorp and in the industry generally in understanding the interactions between wind
resources and utility systems. PacifiCorp has worked for over five years to quantify the costs
associated with integrating wind into its system. As the amount of wind on the system increases
it becomes ever more important for the utility to take operational actions to ensure that the
system is capable of reliably integrating the amount of intermittent power anticipated. Resource
variability can increase the intra hour regulation and load following requirements of the control
area and increase overall ancillary service costs. As large blocks of variable resources are added
to the system, new reserve resources capable of compensating for the intra hour variability may
be required to insure system reliability.
Toward that end, the following action items are proposed:
Action Item:Continue an active role in the regional Northwest Power and Conservation
Council Wind Integration efforts, and support the work of the American
Wind Energy Association (A WEA) and the Utility Wind Integration
Group.
Action Status: PacifiCorp has participated in the Wind Integration efforts which
subsequently issued the Northwest Wind Integration Action Plan in April
2007. Sixteen specific actions are identified. PacifiCorp will continue to
participate in the newly chartered Northwest Wind Integration Forum
whose role it is to provide leadership through the prescribed actions.
Action Item: Continue to refine day-ahead hourly wind forecasts into daily system
planning and scheduling.
Action Status: PacifiCorp has entered into a three-year contact to provide wind
generation forecasts effective April 1 , 2007. PacifiCorp will be gathering
data to determine the value of the forecast.
Action Item: A wind penetration study to reappraise wind integration costs and cost-
effective renewable energy levels will be completed in the 2007 IRP.
Action Status: In the 2007 IRP, Appendix J, PacifiCorp builds on earlier studies with
upgraded and updated wind generation data. The benefits of geographic
diversity, contribution to peak capacity, and the cost of incremental
reserves are considered. Estimates of integration costs are consistent with
earlier studies.
Transmission Action Items
PacifiCorp plans to facilitate the acquisition of wind projects through construction of new cost-
effective transmission facilities. Two transmission paths have been identified: Path C from
southeast Idaho into northern Utah, and Walla Walla to Yakima area loads. These paths are
potentially cost-effective projects that can help to facilitate the development of economic wind
projects.
Action Item a): Complete Walla Walla to Yakima area transmission upgrade by end of
2010 if cost-effective.
b): Complete Path C upgrade by end of2010 if cost-effective.
c): An assessment of transmission options for PacifiCorp system
identified in the Rocky Mountain Area Transmission Study (RMA TS),
scenario 1 related to facilitating additional generation at Jim Bridger
and, on equal footing, new cost-effective wind resources. An assessment
of transmission options will be completed in the 2007 IRP.
Action Status:Transmission reviews have found that both of the planned transmission
upgrades (Walla Walla to Yakima and the Path C Upgrade) are cost
effective. These projects are in progress and expected to be available by
the end of2010.
In addition to the two transmission lines listed above, the 2007 IRP
considered many transmission options and selected several new line
segments from the Bridger area and throughout Utah to be available in
2012 and beyond. This new transmission would support the construction
of new resources in Utah and Wyoming including Wyoming wind
resources. The details are provided in Table 4, below.
Table 4
Transmission Resource Investment Schedule for All Group 2 Portfolios
Transfer Capability, Me2awatts
Resource 2007 2008 2009 2010 2011 2012 2013 2014 2015 2016
East Path C Upgrade: Borah to Path-C South to Utah North 300
Utah - Desert Southwest (Includes Mona - Oquirrh)600
Mona - Utah North 400
Craig-Hayden to Park City 176
Miners - Jim BridJ!;er - Tenninal 600
Jim Bridger - Tenninal 500
West Walla Walla - Yakima 400
West Main - Walla Walla 630
Total Annual Additions 700 630 776 500
Source: PacifiCorp s 2007 IRP, Table 7.36
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