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HomeMy WebLinkAbout20160120Referenced Compliance Filing.pdfROCKY MOUNTAIN PO'IIER A TXVISION OF MOFrcORP RECIll,/i: il 2016 JAH 20 fil{ 11,25 ItlAl-lC i-'i- '.ii-'L UT ILITIES CCIMI'4 ISSIOi{ 1407 W. North Temple, Suite 310 Salt Lake City, Utah 84116 January 20,2016 VA OVERNIGHT DELIVERY Idaho Public Utilities Commission 472West Washington Boise,ID 83702 Attn: Jean Jewell Commission Secretary Re: PacifiCorp Case No. PAC-E-07-07 Compliance Filing Dear Ms. Jewell: Rocky Mountain Power, a division of PacifiCorp ("the Company"), in compliance with Order No. 30497 in Case No. PAC-E-07-07 hereby submits a copy of the 2014 Wind Integration Study ("WIS") prepared as part of the Company's 2015 Integrated Resource Plan ("[U"';. In the stipulation approved by Order No. 30497, the parties agreed that "Rocky Mountain Power shall hereafter file notice with the Commission of any changes to its wind integration charge as reflected in subsequent changes to its IRP." On March 3l,2Ol5 PacifiCorp filed its 2015 IRPI with the Commission, and on October 9,2015 the Commission acknowledged2 the Company's IRP. Volume II, Appendix H of the 2015 IRP contains the2014 Wind lntegration Study. The 2014 Wind Integration Study calculates a wind integration rate of $3.06 per MWh. Table H.3 - Wind Integration Costs from Volume II, Appendix H of the 2015 IRP is provided in support of these wind integration costs. Table IL3- Wind Integration Cost, $/MWh The stipulation approved in Order No. 30497 instituted a wind integration adjustnent to published avoided cost rates for wind qualifying facilities ("QFs"). Wind integration costs were further updated in Case No. PAC-E-09-07. The Company proposes that the wind integration I Case No. PAC-E-15-04. 'Order No. 33396. Idaho Public Utilities Commission January 20,2016 Page2 adjusfinent to published avoided cost rates for wind QFs be updated to reflect the costs in the 2014 Wind Integration Study. Please direct any informal inquiries to Ted Weston, Idaho Regulatory Affairs Manager, at (801) 220-2963. Sincerely, \n44^y f *,rrtau,ul ctu) Jeffrey K. Larsen Vice President, Regulation PACIFICoRP_2015 IRP APPENDX H_ WTND INTEGRATIoN ApppNDIx H _ WINp INTpCRATION Sruoy This wind integration study (WIS) estimates the operating reserves required to both maintain PacifiCorp's system reliability and comply with North American Electric Reliability Corporation (NERC) reliability standards. The Company must provide sufficient operating reserves to meet NERC's balancing authority area control error limit (BAL-001-2) at all times, incremental to contingency reserves, which the Company maintains to comply with NERC standard BAL-002- WECC-2.22'23 Apart from disturbance events that are addressed through contingency reserves, these incremental operating reserves are necessary to maintain area control errol* (ACE), due to sources outside direct operator control including intra-hour changes in load demand and wind generation, within required parameters. The WIS estimates the operating reserve volume required to manage load and wind generation variation in PacifiCorp's Balancing Authority Areas (BAAs) and estimates the incremental cost of these operating reserves. The operating reserves contemplated within this WIS represent regulating margin, which is comprised of ramp reserve, extracted directly from operational data, and regulation reserve, which is estimated based on operational data. The WIS calculates regulating margin demand over two common operational timeframes: l0-minute intervals, called regulating; and one-hour- intervals, called following. The regulating margin requirements are calculated from operational data recorded during PacifiCorp's operations from January 2012 through December 2013 (Study Term). The regulating margin requirements for load variation, and separately for load variation combined with wind variation, are then applied in the Planning and Risk (PaR) production cost model to determine the cost of the additional reserve requirements. These costs are attributed to the integration of wind generation resources in the 2015 Integrated Resource Plan (tRP). Estimated regulating margin reserve volumes in this study were calculated using the same methodology applied in the Company's 2012 WtSz5, with data updated for the current Study Term. The regulating margin reserve volumes in this study account for estimated benefits from PacifiCorp's participation in the energy imbalance market (EIM) with the California Independent System Operator (CAISO). The Company expects that with its participation in the EIM future wind integration study updates will benefit as PacifiCorp gains access to additional and more specifi c operating data. 22 NERC Standard BAL-001-2: http://www.nerc.com/files/BAl-001-2.pdf 23 NERC Standard BAL-002-WECC-2 (http://www.nerc.com/files/BAl-002-WECC-2.ed0, which became effective October 1,2074, replaced NERC Standard BAL-STD-0O2. which was in effect at the time of this study. 24 "AteaControl Error" is defined in the NERC glossary here: htto://www.nerc.com/oalstand/glossarv of terms/slossary_olterms.pdf 2s 2Ol2 WIS report is provided as Appendix H in Volume II of the Company's 2013 IRP report: htto://www.pacificorp.com/content/dam/nacificorp/doc/Enere), Sources/Intesrated_Resource Plar/20l3IRP/Pacifi Corp-20l3IRP Vol2-AppendicesJ-30- l3.pdf 97 PecnrCoru-2015 IRP APPENDX H- WTND INTEGRATIoN Technical Review Committee As was done for its 2012 WIS, the Company engaged a Technical Review Committee (TRC) to review the study results from the 2014 WIS. The Company thanks each of the TRC members, identified below, for their participation and professional feedback. The members of the TRC are: Andrea Coon - Director, Western Renewable Energy Generation Information System (WREGIS) for the Western Electricity Coordinating Council (WECC) Matt Hunsaker - Manager, Renewable Integration for the Western Electricity Coordinating Council (WECC) Michael Milligan - Lead research for the Transmission and Grid Integration Team at the National Renewable Energy Laboratory NREL) J. Charles Smith - Executive Director, Utility Variable-Generation Integration Group (uvrG) Robert Zavadil - Executive Vice President of Power Systems Consulting, EnerNex In its technical review of the Comp-any's 2012 WIS, the TRC made recommendations for consideration in future WIS updates.'o The following table summarizes TRC recommendations from the 2012 WIS and how these recommendations were addressed in the 2014 WIS. 26 TRC's full report is provided at: http://www.nacificorp.com/content/dan/pacificom/doclEnersy Sources/lnteerated-Resource Plar/Wind-Integratio n/20 I 2WlS/Pacificom-2O I 2WIS-TRC-Technical-Memo-5- I 0- l3.pdf Table H.l - 2012 WIS TRC Recommendations The Company modeled reseryes on an hourly basis in PaR. A sensitivity was performed to model reseryes on basis as in the 2012 WIS. Reserve requirements should be modeled on an hourly basis in the production cost model, rather than on a In discussing this recommendation with the TRC, it was clarified that the intent was a request to better explain how the exceedance level ties to operations. PacifiCorp has included discussion in this 2014 WIS on its selection of a99.7%o exceedance level when calculating regulation reserve needs, and further clarifies that the WIS results informs the amount of regulation reseryes planned for Either the 99.1o/o exceedance level should be studied parametrically in future work, or a better method to link the exceedance level, which drives the reserve requirements in the WIS, to actual reliability requirements should be developed. Future work should treat the categories "regulating," "following," and "ramping" differently by using the capabilities already in PaR and comparing these results to those usins of the A sensitivity study was performed demonstrating the impact of separating the reserves into different categories. PacifiCorp appreciates the TRC comment; however, PacifiCorp continued to rely on spreadsheet-based calculations when calculating regulation reserves for its 2014 WIS. This allows stakeholders, who may not have access to specific statistics packages, to review work ins PacifiCorD's 2014 WIS. Given the vast amount of data used, a simpler and more transparent analysis could be performed using a flexible statistics package rather than spreadsheets. 98 PACIFICoRP _ 2OI5 IRP AppBrrrorx H - WIND INTEGRATIoN Because changes in forecasted natural gas and electricity prices were a major reason behind the large change in integration costs from the 2010 WIS, sensitivity studies around nafural gas and power prices, and around carbon tax assumptions, would be interesting and provide some useful results. Changes in wind integration costs continue to align with movements in forward market prices for both natural gas and electricity. PacifiCorp describes how market prices have changed in relation to wind integration costs as updated in the 2014 WIS. With the U.S. Environmental Protection Agency's draft rule under gl I l(d) of the Clean Air Act, CO2 tax assumptions are no longer s official forward price curves. Although the study of separate east and west BAAs is useful, the WIS should be expanded to consider the benefits of PacifiCorp's system as a whole, as some reseryes are transferrable between the BAAs. It would be reasonable to conclude that EIM would decrease reserve requirements and intesration costs. PacifiCorp has incorporated estimated regulation reserye benefits associated with its participation in EIM in the 2014 WIS. With its involvement in EIM, future wind studies will benefit as PacifiCorp gains access to better operating data. Executive Summary The 2014 WIS estimates the regulating margin requirement from historical load and wind generation production data using the same methodology that was developed in the 2012 WIS. The regulating margin is required to manage variations to area control error due to load and wind variations within PacifiCorp's BAAs. The WIS estimates the regulating margin requirement based on load combined with wind variation and separately estimates the regulating margin requirement based solely on load variation. The difference between these two calculations, with and without the estimated regulating margin required to manage wind variability and uncertainty, provides the amount of incremental regulating margin required to maintain system reliability due to the presence of wind generation in PacifiCorp's BAAs. The resulting regulating margin requirement was evaluated deterministically in the PaR model, a production cost model used in the Company's Integrated Resource Plan (IRP) to simulate dispatch of PacifiCorp's system. The incremental cost of the regulating margin required to manage wind resource variability and uncertainty is reported on a dollar per megawatt-hour ($/lrrtWtr; of wind generation basis.27 When compared to the result in the 2012 WIS, which relied upon 201I data, the 201,4 WIS uses 2013 data and shows that total regulating margin increased by approximately 27 megawatts (MW) in 2012 and 47 MW in 2013. These increases in the total reserve requirement reflect different levels of volatility in actual load and wind generation. This volatility in turn impacts the operational forecasts and the deviations between the actual and operational forecast reserve requirements, which ultimately drives the amount of regulating margin needed. Table H.2 depicts the combined PacifiCorp BAA annual average regulating margin calculated in the 2014 WIS, and separates the regulating margin due to load from the regulating margin due to wind. The total regulating margin increased from 579 MW in the 2012 WIS to 626 MW in the 2014 WIS. 2'The PaR model can be run with stochastic variables in Monte Carlo simulation mode or in deterministic mode whereby variables such as natural gas and power prices do not reflect random draws from probability distributions. For purposes of the WIS, the intention is not to evaluate stochastic portfolio risk, but to estimate production cost impacts of incremental operating reserves required to manage wind generation on the system based on current projections of future market prices for power and natural gas. 99 PACIFICoRP_2OI5IRP AppeNpx H _ WTND INTEGRATIoN Table H.2 - Average Annual Regulating Margin Reserves, 2011- 2013 (MW) 20tt (2012 WrS) Load-Only Regulating Margin 147 247 394 Incremental Wind Regulating Margin 54 131 185 Total Rezulatins Margm 202 378 579 Wind Capaciw 589 1,536 2,126 2012 Load-Onlv Regulating Margin 141 259 400 lncremental Wind Reeulating Marsin 77 129 206 Total Resulatine Maxein 217 388 606 Wind Capacity 785 1,759 2,543 2013 (2014 wrs) Load-Onlv Reeulatine Marein 166 275 441 Incremental Wind Regulating Margin 55 130 186 Total Resulatins Marsin 222 40s 626 Wind CanaciW 785 1,759 2,543 Table H.3 lists the cost to integrate wind generation in PacifiCorp's BAAs. The cost to integrate wind includes the cost of the incremental regulating margin reseryes to manage intra-hour variances (as outlined above) and the cost associated with day-ahead forecastvariances, the latter of which affects how dispatchable resources are committed to operate, and subsequently, affect daily system balancing. Each of these component costs were calculated using the PaR model. A series of PaR simulations were completed to isolate each wind integration cost component by using a "with and withouf' approach. For instance, PaR was first used to calculate system costs solely with the regulating margin requirement due to load variations, and then again with the increased regulating margin requirements due to load combined with wind generation. The change in system costs between the two PaR simulations results in the wind integation cost. Table H.3 - Wind Integration Cost, $/lVIWh The 2014 WIS results are applied in the 2015 IRP portfolio development process as part of the costs of wind generation resources. In the portfolio development process using the System Optimizer (SO) model, the wind integration cost on a dollar per megawatt-hour basis is included as a cost to the variable operation and maintenance cost of each wind resource. Once candidate resource portfolios are developed using the SO model, the PaR model is used to evaluate the risk profiles of the portfolios in meeting load obligations, including incremental operating reserve needs. Therefore, when performing IRP risk analysis using PaR, specific operating reserve requirements consistent with this wind study are used. 100 PlcnrConp-2015IRP APPENDX H - WTND INTEGRATION The calculation of regulating margin reserve requirement was based on actual historical load and wind production data over the Study Term from January 2012 through December 2013. Table H.4 outlines the load and wind generation lO-minute interval data used during the Study Term. Table H.4 - Historical Wind Production and Load Data Inventory Chewon Wind 16.5 t/U2012 t2t3t/2013 East Combine Hills 41.0 uy20t2 t2l3t/2013 West Dunlap I Wind 111.0 t/u2012 t2t3v20t3 East Five Pine and North Point 119.7 12/U2012 t2/3U2013 East Foot Creek Generation 85.1 l1/20 2 l2/3t/2013 East Glenrock III Wind 39.0 lt/20 2 t2t3y20t3 East Glenrock Wind 99.0 Ut/20 2 2t3t/2013 East Goodnoe Hills Wind 94.0 t/t/20 2 2/31/2013 West Hieh Plains Wind 99.0 Ut/20 2 2131/2013 East Leanins Juniper I 100.5 yU20 )2/3y2013 West Marenso I 140.4 Uu20 2 2t3,/2013 West Marenso II 70.2 t/t/20 2 2t3y2013 West McFadden Ridse Wind 28.5 lt/20 2 213,/2013 East Mountain Wind I OF 60.9 t/t/20 2 2/3U2013 East Mountain Wind 2 OF 79.8 Ut/20 2 2t3t/2013 East Power Countv North and Power County South 45.0 r/y20 2 2/3U2013 East Oreeon Wind Farm OF 64.6 yt/20 2 2t3U2013 West Rock River I 49.0 t/t/20 2 2/3t/2013 East Rollins Hills Wind 99.0 lt/20 2 2l3t/2013 East Seven Mile Wind 99.0 t/t/20 )2t3U2013 East Seven Mile II Wind 19.5 Ut/20 ,)2t3t/2013 East Soanish Fork Wind 2 OF 18.9 t/U20 2 213u2013 East Stateline Contacted Generation 175.0 lt/20 2 2/3U2013 West Three Buttes Wind 99.0 t/U20 2 2t3U2013 East Top of the World Wind 200.2 Uu20 2 t2/3U2013 East Wolverine Creek 64.5 t/t/20 2 t2t3U20t3 East Lone Hollow Wind UU20 2 t213U2013 East Campbell Wind Ut/20 2 tzl3U20t3 West Horse Butte 6lt9l20L2 t2t3U20t3 East Jollv Hills I UU2012 t2/31/2013 East Jollv Hills 2 Uu20t2 t2/31/2013 East PACW Load nla t/t/2012 t2t3t/2013 West PACE Load n/a Ut/2012 tzl3U20t3 East 101 PACIFICoRP-20I5 IRP APPENDIX H _ WIND INTEGRATIoN Historical Load Data Historical load data for the PacifiCorp east (PACE) and PacifiCorp west (PACW) BAAs were collected for the Study Term from the PacifiCorp PI system.28 The raw load data were reviewed for anomalies prior to further use. Data anomalies can include: o Incorrect or reversal of sign (recorded data switching from positive to negative);o Significant and unexplainable changes in load from one lO-minute interval to the next;o Excessive load values. After reviewing 210,528 lO-minute load data points in the 2014 WIS, 1,011 l0-minute data points, roughly 0.5% of the data, were identified as irregular. Since reserve demand is created by unexpected changes from one time interval to the next, the corrections made to those data points were intended to mitigate the impacts of irregular data on the calculation of the reserve requirements and costs in this study. Of the l,0ll load data points requiring adjustment, 984 exhibited unduly long periods of unchanged or "stuck" values. The data points were compared to the values from the Company's official hourly data. If the six l0-minute PI values over a given hour averaged to a different value than the official hourly record, they were replaced with six l0-minute instances of the hourly value. For example, if PACW's measured load was 3,000 MW for three days, while the Company's official hourly record showed different hourly values for the same period, the six l0- minute "stuck" data points for an hour were replaced with six instances of the value from the official record for the hour. Though the granularity of the lO-minute readings was lost, the hour- to-hour load variability over the three days in this example would be captured by this method. In total, the load data requiring replacement for stuck values represented only 0.47Yo of the load data used in the current study. The remaining2T of data points requiring adjustment were due to questionable load values, three of which were significantly higher than the load values in the adjacent time intervals, and 24 of which were significantly lower. While not necessarily higher or lower by an egregious amount in each instance, these specific irregular data collectively averaged a difference of several hundred megawatts from their replacement values. Table H.5 depicts a sample of the values that varied significantly, as compared to the data points immediately prior to and after those lO-minute intervals. The replacement values, calculated by interpolating the prior value and the successive lO-minute period to form a straight line, are also shown in the table. " The PI system collects load and generation data and is supplied to PacifiCorp by OSISoft. The Company Web site is htto ://www.osisoft .com/software-support/what-is-pi/what is PI .aspx. 102 PACIFICoRP_2015 IRP APPENDIX H _ WIND INTEGRATIoN Table H.5 - Examples of Load Data Anomalies and their Interpolated Solutions ll5l20l212:20 5.80s 5.805 nla ll5l20l212z30 5.211 5.793 12:20 + l/5 of (13:10 minus 12:20) ll5l20l2l2z40 5.074 5.781 12:20 + 215 of (13:10 minus 12:20) 1151201212250 5.063 5.769 12:20 + 3/5 of (13:10 minus l2:20) ll5l20l213:00 5.465 5,756 12:20 + 4/5 of (13:10 minus 12:20\ ll5l20l213:10 5.744 5.744 nla 5/6/2013 8:50 5.651 5.651 nla 51612013 9t00 4,583 5.694 Averase of 8:50 and 9:10 51612013 9:10 5.737 5.737 nla Historical Wind Generation Data Over the Study Term, l0-minute interval wind generation data were available for the wind projects as summarizedin Table H.4. The wind output data were collected from the PI system. In 2011 the installed wind capacity in the PacifiCorp system was 589 MW in the west BAA and 1,536 MW in the east BAA. For 2012 and20l3, these capacities inueased to 785 MW and 1,759 MW in the west and east BAAs, respectively. The increases were the result of 195 MW of existing wind projects transferring from Bonneville Power Administration (BPA) to PacifiCorp's west BAA, and222 MW of new third parfy wind projects coming on-line during 2012 in the east BAA. Figure H.l shows PacifiCorp owned and contracted wind generation plants located in PacifiCorp's east and west BAAs. The third-party wind plants located within PacifiCorp's BAAs which the Company does not purchase generation from or own are not depicted in this figure. 103 PACIFICORP-20I5 IRP APPENDIX H_ WIND INTEGRATION Figure H.l - Representative Map, PacifiCorp Wind Generating Stations Used in this Study !,lOXTAl{A !ill' - F,.: rl{Etffi!:-t9l oltGoia IDAHO um<rtl *;fir-1r,H,,i$(D(Dmr<umremwx(Nwr<mrexrur(!f IIEYAOA :* Fl(&aocffirm ldt trqmh h*!r sfir flr { rutcotgma*narc @Hrxtt:.H coLotaDo u ?l at The wind data collected from the PI system is grouped into a series of sampling points, or nodes, which represent generation from one or more wind plants. In consideration of occasional irregularities in the system collecting the data, the raw wind data was reviewed for reasonableness considering the following criteria: . Incorrect or reversal of sign (recorded data switching from positive to negative);o Output greater than expected wind generation capacity being collected at a given node;o Wind generation appearing constant over a period of days or weeks at a given node. Some of the PI system data exhibited large negative generation output readings in excess of the amount that could be attributed to station service. These meter readings often reflected positive generation and a reversed polarity on the meter rather than negative generation. In total, only 38 of 3,822,048 l0-minute PI readings, representing 0.001% of the wind data used in this WIS, required substituting a positive value for a negative generation value. Some of the PI system data exhibited large positive generation output readings in excess of plant capacity. In these instances, the erroneous data were replaced with a linear interpolation between the value immediately before the start of the excessively large data point and the value immediately after the end of the excessively large data point. In total, only 49 l0-minute PI readings, representing0.002% of the wind data used in this WIS, required substituting a linear interpolation for an excessively large generation value. Similar to the load data, the PI system wind data also exhibited patterns of unduly long periods of unchanged or "stuck" values for a given node. To address these anomalies, the l0-minute PI values were compared to the values from the Company's official hourly data, and if the six l0- minute PI values over a given hour averaged to a different value than the official hourly record, caLtT0illta 104 PACIFICoRP_20I5 IRP APPENDIX H _ WTND INTEGRATION they were replaced with six l0-minute instances of the hourly value. For example, if a node's measured wind generation output was 50 MW for three weeks, while the official record showed different hourly values for the same time period, the six lO-minute oostuck" data points for an hour were replaced with six instances of the value from the official record for the hour. Though the granularity of the l0-minute readings was lost, the hour-to-hour wind variability over the three weeks in this example would be captured by this method. In total, the wind generation data requiring replacement for stuck values represented only 0.2Yo of the wind data used in the WIS. Method Overview This section presents the approach used to establish regulating margin reserve requirements and the method for calculating the associated wind integration costs. l0-minute interval load and wind data were used to estimate the amount of regulating margin reserves, both up and down, in order to manage variation in load and wind generation within PacifiCorp's BAAs. Operating Reserves NERC regional reliability standard BAL-002-WECC-2 requires each BAA to carry sufficient operating reserve at all times." Operating reserve consists of contingency reserve and regulating margin. These reserve requirements necessitate committing generation resources that are sufficient to meet not only system load but also reserve requirements. Each of these types of operating reserve is further defined below. Contingency reserve is capacity that the Company holds in reserve that can be used to respond to contingency events on the power system, such as an unexpected outage of a generator or a transmission line. Contingency reserve may not be applied to manage other system fluctuations such as changes in load or wind generation output. Therefore, this study focuses on the operating reserve component to manage load and wind generation variations which is incremental to contingency reserve, which is referred to as regulating margin. Regulating margin is the additional capacity that the Company holds in reserve to ensure it has adequate reserve at all times to meet the NERC Control Performance Criteria in BAL-001-2, which requires a EAA to carry regulating reserves incremental to contingency reserves to maintain reliability.30 However, these additional regulating reserves are not defined by a simple formula, but rather are the amount of reserves required by each BAA to meet the control performance standards. NERC standard BAL-001-2, called the Balancing Authority Area Control Error Limit (BAAL), allows a greater ACE during periods when the ACE is helping frequency. However, the Company cannot plan on knowing when the ACE will help or exaierbate frequency so the Lro is used for the bandwidth in both directions of the ACE. 31'32 Thus the Company determines, based on the unique level of wind and load variation in its " NERC Standard BAL-002-WECC-2: htto://www.nerc.com/files/BAl-002-WECC-2.ndf 3o NERC Standard BAL-00 I -2:http://www.nerc.com/fi les/BAL-OO I -2.pdf3r The L1s represents a bandwidth of acceptable deviation prescribed by WECC between the net scheduled interchange and the net actual electrical interchange on the Company's BAAs. Subtracting the L1e credits customers with the natural buffering effect it entails. 32 The L1e of PacifiCorp's balancing authority areas are 33.4lMW for the West and 47.88 MW for the East. For more information, please refer to: htto://www.wecc.bizlcommittees/StandingCommittees/OC/OPS/PWG/Shared%o20Documents/Annual%o20Freouenc v%o20BiasYo20Setlinssl20l2o/o20CPS2%o20Botndso/o20Reoort:/o20Final.pdf 105 PecmrConp-2015 IRP APPENDIX H - WIND INTEGRATION system, and the prevailing operating conditions, the unique level of incremental operating reserve it must carry. This reserve, or regulating margin, must respond to follow load and wind changes throughout the delivery hour. For this WIS, the Company further segregates regulating margin into two components: ramp reserve and regulation reserve. Ramp Reserve: Both load and wind change from minute-to-minute, hour-to-hour, continuously at all times. This variability requires ready capacity to follow changes in load and wind continuously, through short deviations, at all times. Treating this variability as though it is perfectly known (as though the operator would know exactly what the net balancing area load would be a minute from now, l0-minutes from now, and an hour from now) and allowing just enough generation flexibility on hand to manage it defines the ramp reserve requirement of the system. Regulation Reserve: Changes in load or wind generation which are not considered contingency events, but require resources be set aside to meet the needs created when load or wind generation change unexpectedly. The Company has defined two types of regulation reserve - regulating and following reserves. Regulating reserve are those covering short term variations (moment to moment using automatic generation control) in system load and wind. Following reserves cover uncertainty across an hour when forecast changes unexpectedly. To summarize, regulating margin represents operating reserves the Company holds over and above the mandated contingency reserve requirement to maintain moment-to-moment system balance between load and generation. The regulating margin is the sum of two parts: ramp reserve and regulation reserve. The ramp reserve represents an amount of flexibility required to follow the change in actual net system load (load minus wind generation output) from hour to hour. The regulation reserve represents flexibility maintained to manage intra-hour and hourly forecast errors about the net system load, and consists of four components: load and wind following and load and wind regulating. Determination of Amount and Costs of Regulating Margin Requirements Regulating margin requirements are calculated for each of the Company's BAAs from production data via a five step process, each described in more detail later in this section. The five steps include: 1. Calculation of the ramp reserve from the historical data (with and without wind generation). 2. Creation of hypothetical forecasts of following and regulating needs from historical load and wind production data. 3. Recording differences, or deviations, between actual wind generation and load values in each lO-minute interval of the study term and the expected generation and load. 4. Group these deviations into bins that can be analyzed for the reserve requirement per forecast value of wind and load, respectively, such that a specified percentage (or tolerance level) of these deviations would be covered by some level of operating reserves. 5. The reserve requirements noted for the various wind and load forecast values are then applied back to the operational data enabling an average reserve requirement to be calculated for any chosen time interval within the Study Term. Once the amount of regulating margin is estimated, the cost of holding the specified reserves on PacifiCorp's system is estimated using the PaR model. In addition to using PaR for evaluating 106 PACIFICORP_2015 IRP APPENDX H _ WTND INTEGRATION operating reserve cost, the PaR model is also used to estimate the costs associated with daily system balancing activities. These system balancing costs result from the unpredictable nature of load and wind generation on a day-ahead basis and can be characterized as system costs borne from committing generation resources against a forecast of load and wind generation and then dispatching generation resources under actual load and wind conditions as they occur in real time. Regulating Margin Requirements Consistent with the methodology developed in the Company's 2012 WIS, and the discussion above, regulating margin requirements were derived from actual data on a l0-minute interval basis for both wind generation and load. The ramp reserve represents the minimal amount of flexible system capacity required to follow net load requirements without any error or deviation and with perfect foresight for following changes in load and wind generation from hour to hour. These amounts are as follows: o If system is ramping down: [(Net Area Load Hour H - Net Area Load Hour (H+l))/2]. If system is ramping up: [(Net Area Load Hour (H+l) - Net Area Load Hour H)/2] That is, the ramp reserve is half the absolute value of the difference between the net balancing area load at the top of one hour minus the net balancing load at the top of the prior hour. The ramp reserve for load and wind is calculated using the net load (load minus wind generation output) at the top of each hour. The ramp reserve required for wind is the difference between that for load and that for load and wind. As ramp reserves represent the system flexibility required to follow the system's requirements without any uncertainty or error, the regulation reserve is necessary to cover uncertainty ever- present in power system operations. Very short-term fluctuations in weather, load patterns, wind generation output and other system conditions cause short term forecasts to change at all times. Therefore, system operators rely on regulation reserve to allow for the unpredictable changes between the time the schedule is made for the next hour and the arrival of the next hour, or the ability to follow net load. Also, these very same sources of instability are present throughout each hour, requiring flexibility to regulate the generation output to the myriad of ups and downs of customer demand, fluctuations in wind generation, and other system disturbances. To assess the regulation reserye requirements for PacifiCorp's BAAs, the Company compared operational data to hypothetical forecasts as described below. Hypothetical Operational Forecasts Regulation reserve consists of two components: (1) regulating, which is developed using the l0- minute interval data, and (2) following, which is calculated using the same data but estimated on an hourly basis. Load data and wind generation data were applied to estimate reserve requirements for each month in the Study Term. The regulating calculation compares observed l0-minute interval load and wind generation to a l0-minute interval forecast, and following compares observed hourly averages to an average hourly forecast. Therefore, the regulation reserve requirements are composed of four component requirements, which, in turn, depend on differences between actual and expected needs. The four component requirements include: load following, wind following, load regulating, and wind regulating. The determination of these 107 P.q.cInrCoRP - 201 5 IRP APPENDIX H - WTND INTEGRATION reserve requirements began with the development of the expected following and regulating needs (hypothetical forecasts) of the four components, each discussed in turn below. Hypothetical Load Following Operational Forecast PacifiCorp maintains system balance by optimizing its operations to an hour-ahead load forecast every hour with changes in generation and market activity. This planning interval represents hourly changes in generation that are assessed roughly 20 minutes into each hour to meet a bottom-of-the-hour (i.e., 30 minutes after the hour) scheduling deadline. Taking into account the conditions of the present and the expected load and wind generation, PacifiCorp must schedule generation to meet demand with an expectation of how much higher or lower load may be. These activities are carried out by the group referred to as the real-time desk. PacifiCorp's real-time desk updates the load forecast for the upcoming hour 40 minutes prior to the start of that hour. This forecast is created by comparing the load in the current hour to the load of a prior similar-load-shaped day. The hour-to-hour change in load from the similar day and hours (the load difference or oodelta") is applied to the load for the current hour, and the sum is used as the forecast for the upcoming hour. For example, on a given Sunday, the PacifiCorp real-time desk operator may forecast hour-to-hour changes in load by referencing the hour-to- hour changes from the prior Sunday, which would be a similar-load-shaped day. If at I l:20 am, the hour-to-hour load changebetween ll:00 a.m. and 12:00 p.m. of the prior Sunday was five percent, the operator will use a five percent change from the current hour to be the upcoming hour's load following forecast. For the calculation in this WIS, the hour-ahead load forecast used for calculating load following was modeled using the approximation described above with a shaping factor calculated using the day from one week prior, and applying a prior Sunday to shape any NERC holiday schedules. The differences observed between the actual hourly load and the load following forecasts comprised the load following deviations. Figure H.2 shows an illustrative example of a load following deviation in August 2013 using operational data from PACE. In this illustration, the delta between hours ll:00 a.m. and 12:00 p.m. from the prior week is applied to the actual load at I l:00 a.m. on the "current day" to produce the hypothetical forecast of the load for the 12:00 p.m. ("upcoming") hour. That is, using the actual load at I l:00 a.m. (beginning of the purple line), the load forecast for the 12:00 p.m. hour is calculated by following the dashed red line that is parallel to the green line from the prior week. The forecasted load for the upcoming hour is the point on the blue line at 12:00 p.m. Since the actual load for the l2:00 p.m. hour (the point on the purple line at l2:00 p.m.) is higher than the forecast, the deviation (indicated by the black arrow) is calculated as the difference between the forecasted and the actual load for 12:00 p.m. This deviation is used to calculate the load following component reserve requirement for 12:00 p.m. 108 PecrnCoRp- 2015 IRP APPENDIX H _ WTND INTEGRATION Figure H.2 - Illustrative Load Following Forecast and Deviation 7,10O 7,m0 6,9m 6,800 6,700 6,600 6,500 6,400 5,300 q20o 6,100 Upcoming hour I 12:m Pi,l 1r0 PM -f>Shnil.rOryDella -For€(est 1r:mAM -Prior week (Acruel)+Actu.l Hypoth etical Wi nd Fo llow ing Operational Forecast The short term hourly operational wind forecast is based on the concept of persistence - using the instantaneous sample of the wind generation output at 20 minutes into the current hour as the forecast for the upcoming hour, and balancing the system to that forecast. For the calculation in this WIS, the hour-ahead wind generation forecast for the "upcoming" hour used the 20th minute output from the "current" hour. For example, if the wind generation is producing 300 MW at 9:20 p.m. in PACE, then it is assumed that 300 MW will be generated between l0:00 p.m. and 11:00 p.m., that same day. The difference between the hourly average of the six 10-minute wind generation readings and the wind generation forecast comprised the wind following deviation for that hour. Figure H.3 shows an illustrative example of a wind following deviation in July 2013 using operational data from PACE. In this illustration, the wind generation output at 9:20 p.m. (within the oocurrent" hour) is the hour-ahead forecast of the wind generation for the 10:00 p.m. hour (the "upcoming" hour). That is, following persistence scheduling, the wind following need for the 10:00 p.m. hour is calculated by following the dashed red line starting from the actual wind generation on the purple line at 9:20 p.m. for the entire 10:00 p.m. hour (blue line). Since the average of the actual wind generation during the 10:00 p.m. hour (dotted green line) is higher than the wind following forecast, the deviation (indicated by the black arrow) is calculated as the 109 PACIFICoRP _ 20I5 IRP APPENDIX H_ WTND INTEGRATION difference between the wind following forecast and the actual wind generation for the l0:00 p.m. hour. This deviation is used to calculate the wind following component reserve requirement for l0:00 p.m. Figure H.3 - Illustrative Wind Following Forecast and Deviation E{I' 7m 6m YD lrmI 3{n 2@ 1@ o rO(D PM 1l:m PM j -Actu.l - - Ar,rralcActu.l6enrl.lhn -->P.rblan(c(9.20pm1 -pS6Folltringforcertl Upcoming houl Hypothetical Load Regulating Operational Forecast Separate from the variations in the hourly scheduled loads, the lO-minute load variability and uncertainty was analyzed by comparing the l0-minute actual load values to a line of intended schedule, represented by a line interpolated between the actual load at the top of the oocurrent" hour and the hour-ahead forecasted load (the load following hypothetical forecast) at the bottom of the "upcoming" hour. The method approximates the real time operations process for each hour where, at the top of a given hour, the actual load is known, and a forecast for the next hour has been made. For the calculation in this WIS, a line joining the two points represented a ramp up or down expected within the given hour. The actual l0-minute load values were compared to the portion of this straight line from the "current" hour to produce a series of load regulating deviations at each l0-minute interval within the "current" hour. Figure H.4 shows an illustrative example of a load regulating deviation in November 2013 using operational data in PACW. In this illustration, the line of intended schedule is drawn from the actual load at 7:00 a.m. to the hour-ahead load forecast at 8:30 a.m. The portion of this line within the 7:00 a.m. hour becomes the load regulating forecast for that hour. That is, using the forecasted load for the 8:00 a.m. hour that was calculated for the load following hypothetical forecast, the line of intended schedule is calculated by following the dashed red line from the actual load at 7:00 a.m. (beginning of the purple line) to the point in the hour-ahead forecast ll0 PecmrConp-20l5IRP Appgrvorx H _ WIND INTEGRATION (green line) at 8:30 a.m. The six l0-minute deviations within the 7:00 a.m. hour (one of which is indicated by the black arrow) are the differences between the actual l0-minute load readings (purple line) and the line of intended schedule. These deviations are used to calculate the load regulating component reserve requirement for the six l0-minute intervals within the 7:00 a.m. hour. Figure H.4 - Illustrative Load Regulating Forecast and Deviation 2,An 2,7tn Tlx)AM 900AM i -Actual -Lo.dtollflln8 - +lntrric.ttiEPm.ml -l,o.d Rr&Llhg rorcc.il | Hypoth etical Wind Regulating Operational Forecast Similarly, the l0-minute wind generation variability and uncertainty was analyzed by comparing the l0-minute actual wind generation values to a line of intended schedule, represented by a line interpolated between the actual wind generation at the top of the "current" hour and the hour- ahead forecasted wind generation (the wind following hypothetical forecast) at the bottom of the "upcoming" hour. For the calculation in this WIS, a line joining the two points represented a ramp up or down expected within the given hour. The actual lO-minute wind generation values were compared to the portion of this straight line from the "current" hour to produce a series of wind regulating deviations at each 10-minute interval within the "current" hour. Figure H.5 shows an illustrative example of a wind regulating deviation in July 2013 using operational data in PACE. In this illustration, the line of intended schedule is drawn from the actual wind generation at 2:00 p.m. to the hour-ahead wind forecast at 3:30 p.m. The portion of this line within the 2:00 p.m. hour becomes the wind regulating forecast for that hour. That is, using the forecasted wind generation for the 3:00 p.m. hour that was calculated for the wind following hypothetical forecast, the line of intended schedule is calculated by following the dashed red line from the actual wind generation at 2:00 p.m. (beginning of the purple line) to the point in the hour-ahead forecast (green line) at 3:30 p.m. The six l0-minute deviations within the ill PACIFICoRP_2015 IRP APPENDIX H - WIND INIEGRATION 2:00 p.m. hour (one of which is indicated by the black arrow) are the differences between the actual l0-minute wind generation readings (purple line) and the line of intended schedule (red line). These deviations are used to calculate the wind regulating component reserve requirement for the six l0-minute intervals within the 2:00 p.m. hour. Figure H.5 - Illustrative Wind Regulating Forecast and Deviation Upcoming lG.minute feriod J +Artual - wird roilouing --+ ht"nd.d t"in. (2oo Fn) -whd i.Sut.ting Fof.(zst Analysis of Deviations The deviations are calculated for each l0-minute interval in the Study Term and for each of the four components of regulation reserves (load following, wind following, load regulating, wind regulating). Across any given hourly time interval, the six 1O-minute intervals within each hour have a common following deviation, but different regulating deviations. For example, considering load deviations only, if the load forecast for a given hour was 150 MW below the actual load realized in that hour, then a load following deviation of -150 MW would be recorded for all six of the l0-minute periods within that hour. However, as the load regulating forecast and the actual load recorded in each 1O-minute interval vary, the deviations for load regulating vary. The same holds true for wind following and wind regulating deviations, in that the following deviation is recorded as equal for the hour, and the regulating deviation varies each lO-minute interval. Since the recorded deviations represent the amount of unpredictable variation on the electrical system, the key question becomes how much regulation reserve to hold in order to cover the deviations, thereby maintaining system reliability. The deviations are analyzed by separating the deviations into bins by their characteristic forecasts for each month in the Study Term. The bins are defined by every 5s percentile of recorded forecasts, creating 20 bins for the deviations in each month for each component hypothetical operational forecast. In other words, each month of the Study Term has 20 bins of load following deviations, 20 bins of load regulating deviations, and the same for wind following and wind regulating. tt2 PACIFICORP _ 2OI5 IRP APPENDX H - WTND INTEGRATIoN As an example, Table H.6 depicts the calculation of percentiles (every five percent) among the load regulating forecasts for June 2013 using PACE operational data. For the month, the load ranged from 4,521 MW to 8,587 MW. A load regulating forecast for a load at 4,892 MW represents the fifth percentile of the forecasts for that month. Any forecast below that value will be in Bin 20, along with the respective deviations recorded for those time intervals. Any forecast values between 4,892 MW and 5,005 MW will place the deviation for that particular forecast in Bin 19. Table H.6 - Percentiles Dividing the June 2013 East Load Regulating Forecasts into 20 Bins MAX 8,587 I 0.95 7.869 2 0.90 7.475 3 0.8s 7.220 4 0.80 6.984 5 0.75 6.807 6 0.70 6.621 7 0.6s 6.482 I 0.60 6,383 9 0.55 6.285 t0 0.50 6.1 58 11 0.45 6.023 t2 0.40 s,850 13 0.3s 5.720 t4 0.30 5.568 15 0.25 s,404 t6 0.20 5.275 17 0.l s s.134 18 0.10 5,005 t9 0.05 4.892 20 MIN 4,s21 Table H.7 depicts an example of how the data are assigned into bins based on the level of forecasted load, following the definition of the bins in Table H.6. ll3 06/0 12013 6:00 4.755 88 20 0610 12013 6:10 4.706 -67 20 0610 /2013 6:20 4.746 -13 20 0610 12013 6:30 4,786 -36 20 0610 /2013 6:40 4.826 -26 20 06/0 12013 6:50 4,866 -46 20 0610 /2013 7:00 4.905 -46 l9 0610 /2013 7:10 4.984 4 l9 0610 12013 7:20 5.016 -8 l8 06/0 12013 7:30 s.048 -10 l8 06/0 /2013 7:40 5,081 t6 l8 0610 /2013 7:50 s.l l3 3l l8 06/0 /2013 8:00 5.r45 t2 t7 0610 12013 8:10 s.1 58 16 t7 06/0 12013 8:20 5.182 -22 t7 0610 12013 8:30 5.207 -6 t7 06/0 12013 8:40 5.23r 4 t7 06/0 12013 8:50 5.256 18 t7 06/0 12013 9:00 5.280 10 16 06/0 12013 9:10 s.278 -30 t6 06/0 12013 9:20 5.287 ll l6 06/0 12013 9:30 5-295 2 t6 0610 12013 9:40 5,303 25 r6 0610 12013 9:50 s.31 I -4 16 PACIFICoRP_2OI5IRP APPENDX H _ WTND INTEGRATION Table H,7 - Recorded Interval Load Regulating Forecasts and their Respective Deviations for June 2013 Operational Data from PACE The binned approach prevents over-assignment of reserves in different system states, owing to certain characteristics of load and wind generation. For example, when the balancing area load is near the lowest value for any particular day, it is highly unlikely the load deviation will require substantial down reserves to maintain balance because load will typically drop only so far. Similarly, when the load is near the peak of the load values in a month, it is likely to go only a liule higher, but could drop substantially at any time. Similarly for wind, when wind generation output is at the peak value for a system, there will not be a deviation taking the wind value above that peak. [n other words, the directional nature of reserve requirements can change greatly by the state of the load or wind output. At high load or wind generation states, there is not likely to be a significant need for reserves covering a surprise increase in those values. Similarly, at the lowest states, there is not likely to be a need for the direction of reserves covering a significant shortfall in load or wind generation. Figure H.6 shows a distribution of deviations gathered in Bin 14 for forecast load levels between 5,569 MW and 5,720 MW in June 2013. All of the deviations fall between -170 MW and +370 MW. Such deviations would need to be met by resources on the system in order to maintain the balance of load and resources. That is, when actual load is 170 MW lowerthan expected, there needs to be additional resources that are capable of being dispatched down, and when actual load is 370 MW higher than expected, there needs to be additional resources that are capable of being dispatched up to cover the increases in load. tt4 PACIFICoRP-2015 IRP APPENDIX H _ WTND INTEGRATION Figure H.6 - Histogram of Deviations Occurring About a June 2013 PACE Load Regulating Forecast between 5,568 MW and 5,720 MW (Bin 14) r$ f to z^ f ,rs rs $ * N *.rs$o.ls$s$rSnlotro4ofF+o+orqo$o Devletlon Slze,IlflfV Up and down deviations must be met by operating reserves. To determine the amount of reserves required for load or wind generation levels in a bin, a tolerance level is applied to exclude deviation outliers. The bin tolerance level represents a percentage of component deviations intended to be covered by the associated component reserve. In the absence of an industry standard which articulates an acceptable level of tolerance, the Company must choose a guideline that provides both cost-effective and adequate reserves. These two criteria work against each other, whereby assigning an overly-stringent tolerance level will lead to unreasonably high wind integration costs, while an overly-lax tolerance level incurs penalties for violating compliance standards. Two relevant standards, CPSI and BAAL, address the reliability of control area frequency and error. The compliance standard for CPSI (rolling l2-month average of area frequency) is 100%, while the minimum compliance standard for BAAL is a 30- minute response. Working within these bounds and considering the requirement to maintain adequate, cost-effective reserves, the Company plans to a three-standard deviation (99.7 percent) tolerance in the calculation of component reserves, which are subsequently used to inform the need for regulating margin reserves in operations. In doing so, the Company strikes a balance between planning for as much deviation as allowable while managing costs, uncertainty, adequacy and reliability. Despite exclusion of extreme deviations with the use of the 99.7 percent tolerance, the Company's system operators are expected to meet reserve requirements without exception. The binned approach is applied on a monthly basis, and results in the four component forecast values (load following, wind following, load regulating, wind regulating) for each l0-minute interval of the Study Period. The component forecasts and reserve requirements are then applied 20 l52 a ta o L3 Iz o lJ- . S ..+ ,+ 115 PACIFICoRP_20I5IRP APPENDIX H _ WTND INTEGRAToN back to the operational data to develop summary level information for regulation reserve requirements, using the back casting procedure described below. Back Casting Given the development of component reserve requirements that are dependent upon a given system state, reserve requirements were assigned to each l0-minute interval in the Study Term according to their respective hypothetical operational forecasts to simulate the component reserves values as they would have happened in real-time operations. Doing so results in a total reserve requirement for each interval informed by the data. To perform the back casts, component reserye requirements calculated from the bin analysis described above are first turned into reference tables. Table H.8 shows a sample (June 2013, PACE) reference table for load and wind following reserves at varying levels of forecasted load and wind generation, and Table H.9 shows a sample (June 2013, PACE) reference table for load and wind regulating reserves at varying forecast levels. Table H.8 - Sample Reference Table for East Load and Wind Following Component Reserves (MW) 266 10000 283 358 5000 157 I 266 784r 283 3s8 1061 157 2 250 7528 192 348 940 213 5 200 7220 285 512 839 205 4 315 7005 294 298 755 290 5 262 6804 334 356 698 207 6 150 6626 321 198 627 231 7 280 6s06 260 239 571 375 8 l9l 6381 212 332 s02 308 9 147 6265 135 238 4?8 284 0 273 6168 99 195 395 374 I 237 6017 168 163 355 172 I 199 5859 338 166 302 241 J 279 5719 295 lls 262 264 4 124 5574 l5l tt4 226 203 5 87 5406 195 l0l t97 287 6 144 5264 171 84 163 326 7 179 5125 98 90 122 225 8 102 4991 86 44 78 242 9 87 4870 t)35 47 288 20 290 4505 63 41 -7 8l 290 0 63 4t -7 8l lt6 PACIFICoRP_20I5IRP APPENDIX H _ WTND INTEGRATIoN Table H.9 - Sample Reference Table for East Load and Wind Regulating Component Reserves Each of the relationships recorded in the table is then applied to hypothetical operational forecasts. Building on the reference tables above, the hypothetical operational forecasts described in the previously sections were used to calculate a reserve requirement for each interval of historical operational data. This is clarified in the example outlined below. Application to Component Reserves For each time interval in the Study Term, component forecasts developed from the hypothetical forecasts are used, in conjunction with Table H.8 and Table H.9, to derive a recommended reserve requirement informed by the load and wind generation conditions. This process can be explained with an example using the tables shown above and hypothetical operational forecasts from June 2013 operational data for PACE. Table H.l0 illustrates the outcome of the process for the load following and regulating components. t77 10000 261 373 10000 173 1 177 7869 261 373 1070 173 2 254 7475 183 459 935 228 5 l6l 7220 189 297 827 203 4 255 6984 222 277 762 306 5 271 6807 271 393 695 277 6 327 6621 253 233 628 219 7 232 6482 213 305 562 372 8 182 6383 164 279 508 22s 9 179 6285 143 t7't MO 233 l0 210 6158 158 172 394 406 ll 258 6023 260 l3l 351 t4s t2 225 5850 448 134 30s 168 13 237 5720 431 t44 264 224 t4 149 5568 3s3 tt2 229 158 l5 163 5404 231 85 196 279 16 153 5275 104 74 t62 494 l7 96 5134 125 76 116 240 l8 69 5005 llr 44 82 94 t9 51 4892 97 38 46 154 20 179 4521 87 2t -7 112 179 0 87 21 -7 t12 tt7 PacrrrConp - 2015 IRP AppeNorx H WIND INTEGRATToN Table H.10 - Load Forecasts and Component Reserve Requirement Data for Hour-ending ll:00 a.m. June 1,2013 in PACE The load following forecast for this particular hour (hour ending I l:00 a.m.) is 5,344 MW, which designates reserve requirements from Bin l6 as depicted (with shading for emphasis) in Table H.8. Because the 5,344 MW load following forecast falls between 5,264 MW and 5,406 MW, the value from the higher bin, 144 MW, as opposed to 87 MW, is assigned for this period. Note the same following forecast is applied to each interval in the hour for the purpose of developing reserve requirements. The first l0 minutes of the hour exhibits a load regulating forecast of 5,319 MW, which designates reserve requirements from Table H.9, Bin 16. Note that the load regulating forecast changes every 10 minutes, and as a result, the load regulating component reserve requirement can change very ten minutes as well-although, this is not observed in the sample data shown above. A similar process is followed for wind reserves using Table H.11. Table H.11 - Interval Wind Forecasts and Component Reserve Requirement Data for Hour-ending 11 a.m. June 1,2013 in PACE The wind following forecast for this particular hour (hour ending I I :00 a.m.) is 207 MW, which designates reserve requirements from Bin l5 under wind forecasts as depicted in Table H.8. Note the following forecast is applied to each interval in the hour for developing reserve requirements. Meanwhile, the regulating forecast changes every 10 minutes. The first l0 minutes of the hour Erst Actud Loed (10-min Avg) MW Actud Loed (IIourly Avg) MW Following Forccrst Loed MW Loed following Up Rcscrvcs Spccificd by Tolcmncc Lcvcl MW Lord Following Down Rcscrvcg Spccified by Tolcrrnc c Lcvcl MW Rcgulrting Loed Forccrst MW Lord Rcgulatin 8up Rescrves Spccificd by Tolcrencc Lcvcl MW Lord Regulrtin g Ilown Rcservcs Spocificd by Tolcrencc Lcvcl Mlf,,l 06/01/2013 l0:00 5.117 s.395 5^344 144 t7l 5.31 9 153 104 06/01/2013 l0:10 s.383 s 1qs J i44 144 t7t 5.350 153 104 06/01/2013 l0:20 s.3 86 5.3 95 5.344 144 t7t 5.363 r53 104 06/01/2013 l0:30 5.403 5.395 5.344 144 t7t 5.375 1s3 104 06/01/2013 10:40 ).4JJ 5.395 5.344 144 l7t 5.3 88 153 104 06/01/2013 l0:50 5.428 5.3 95 5.344 144 t7t 5 40t 153 104 E.st Time Actual Wlnd (10- nin Awol Actud Wind (Hourly Awol FolloMng Forccrst lVind: Wind Follow Up Rcscrvcs Specified by Tolerancc Lcvel Wind Follow Down Rccarvcs Spccilicd by Tolcrrncc Lcvcl EestWind Rcgulating tr'nrecrst: rilind Rcguleting Up Reservcs Specificd by Tolcrencc f rvrl. Wind Regulrtin g Down Rcscrves Spccified by Tolerance f .rwel. 06/01/2013 l0:00 190 217 207 l0l 287 219 85 279 06/01/2013 l0:10 208 211 207 101 287 r93 74 494 06/01/2013 l0:20 212 217 201 IOI 287 195 74 494 06/01/2013 10:30 23 I 21',7 207 l0l 287 198 85 279 06/01/2013 l0:40 234 2t'7 207 I01 287 200 85 279 06/01/2013 10:50 226 zt7 20'1 t0l 287 203 85 219 ll8 PecrrCoRp-2015IRP APPENDIX H _ WTND INTEGRATIoN exhibits a wind regulating forecast of 219 MW, which designates reserve requirements from Bin 15 as depicted in Table H.9. Similar to load, the wind regulating forecast changes every l0 minutes, and as a result, the wind regulating component reserve requirement may do so as well. In this particular case, the second interval's forecast (193 MW) shifts the wind regulating component reserve requirement from Bin 15 into Bin 16, per Table H.9, and the component reserve requirement changes accordingly. The assignment of component reserves using component hypothetical operational forecasts as described above is replicated for each l0-minute interval for the entire Study Term. The load following reserves, wind following reserves, load regulating reserves, and wind regulating reserves are then combined into following reserves and regulating reserves. Given that the four component reserves are to cover different deviations between actual and forecast values, they are not additive. In addition, as di-scussed in the Company's 2012 WIS report, the deviations of load and wind are not correlated.33 Therefore, for each time interval, the wind and load reserve requirements are combined using the root-sum-of-squares (RSS) calculation in each direction (up and down). The combined results are then adjusted as the appropriate system L1e is subtracted and the ramp added to obtain the final result: Load Regulatingiz + Wind Regulatingiz + Load Followingt2 + Wind Fottowingiz - Ln * Ramp, where i represents a l0-minute time interval. Assuming the ramp reserve for the 10:00 a.m. is 50 MW, and drawing from the first lO-minute interval in the example H.l0 and Table H.l1. Load Regulatingi: 153 MW Wind Regulating; = 85 MW Load Followingi: 144 MW Wind Followingi: l0l MW East System Lro:48 MW East Ramp; = 50 MW, The regulating margin for l0:00 a.m. is determined as: @-4g+11=ZSLMW In this manner, the component reserve requirements are used to calculate an overall reserve requirement for each l0-minute interval of the Study Term. A similar calculation is also made for the regulating margin pertaining only to the variability and uncertainty of load, while assuming zero reserves for the wind components. The incremental reserves assigned to wind generation are calculated as the difference between the total regulating margin requirement and the load-only regulating margin requirement. 33 The discussion starts on page I I I of Appendix H in Volume II of the Company's 2012 IRP report: htto://www.pacificorp.com/contenVdam/pacificorp/doc/Energ.v-SourcesAnteemted_Resource_Plar/20l3IRP/Pacifi Cofe-20l3lRP_Vol2-Aependices 4-30- l3.pdf east at in Table ll9 PACIFICoRP_2015 IRP APPENDX H - WIND INTEGRATION Application of Regulating Margin Reserves in Operations The methodology for estimating regulating margin requirements described above subsequently informs the projected regulating margin needs in operations. PacifiCorp applies the data from the reserve tables, as depicted in Table H.8 and Table H.9, to derive regulating margin requirements within its energy trading system, which is used to manage PacifiCorp's electricity and natural gas physical positions. As such, the regulating margin requirements derived as part of this wind integration study are used when PacifiCorp schedules system resources to cost effectively and reliably meet customer loads. In operations, scheduling system resources to meet regulating margin requirements ensures that PacifiCorp can meet the BAAL reliability standard. This standard is tied to real-time system frequency, and as this frequency fluctuates, real-time operators use regulating margin reserves to maintain or correct frequency deviations within the allowable 30-minute period, 100% of the time. Determination of Wind Integration Costs Wind integration costs reflect production costs associated with additional reserve requirements to integrate wind in order to maintain reliability of the system, and additional costs incurred with daily system balancing that is influenced by the unpredictable nature of wind generation on a day-ahead basis. To characterize how wind generation affects regulating margin costs and system balancing costs, PacifiCorp utilizes the Planning and Risk (PaR) model and applies the regulating margin requirements calculated by the method detailed in the section above. The PaR model simulates production costs of a system by committing and dispatching resources to meet system load. For this study, PacifiCorp developed seven different PaR simulations. These simulations isolate wind integration costs associated with regulating margin reserves and system balancing practice. The former reflects wind integration costs that arise from short-term variability (within the hour and hour ahead) in wind generation and the latter reflects integration costs that arise from effors in forecasting wind generation on a day-ahead basis. The seven PaR simulations used in the WIS are summarized in Table H.12. 120 PACIFICoRP _ 2015 IRP AppgNUX H_ WTND INTEGRATION Table H.l2 - Wind Integration Cost Simulations in PaR Reculith! Merllr Reserve Coit Rmr I 2015 2015lnad Forecast Eryected Profle tad Norp 2 2015 2015 toad Forecast Expected Profile Load ad Wind None ?equlating Marpin Cost : System Cost from PaR Simulation 2 less System Cost from PaR Simulation l lwtcmBelerclnq ColtRrB J 2015 2013 Day-ahead Forecast 2013 Day-ahead Forecast Yes None Comnit urits based on day-ahead load furecast, ad day-ahead wird frrecast 4 2015 2013 Actual 2013 Actual Yes For Load ard Wird Apply conrnimrm fiom Sirulation 3 5 20ts 2013 Acfial 2013 Day-ahead Forecast Yes Norp Comnit units based on achal Load, ard dav-ahead wird forecasr 6 2015 2013 Achnl 2013 Actual Yes ForWird AppV conrniErEnt from Simuhtbn 5 7 2015 2013 Actul 2013 Achnl Yes Norn Conmit units based on actual toad, and ach:alwird furecast ,oad System Bahrcing Cos = System Cost from PaR Simulation 4, whbh tses the unit conmiErsfi from Simuhtion 3 based on day-ahead furecast bad (ard day-alrcad wird) less System Cost fiom PaR Simuhtbn 6, which rses the mit conrniterEnt from Simulatbn 5 based on actr:al load (ard dav-a}ead wird) ilind System Balarrcing Cost = System Cost fiom PaR Simulatbn 6, which uses the urit conrnitrBnt tom Simulation 5 based on day-aMead wfud (ard actual load) less System Cost fiom PaR Simulatbn 7, whbh conrnits units based on actral wid (ard acugl load) The first two simulations are used to determine operating reserve wind integration costs in forward planning timeframes. The approach uses "P50", or expected, wind generation profiles and forecasted loads that are applicable to 2015.34 Simulation I includes only the load regulating margin reserves. Simulation 2 includes regulating margin reserves for both load and wind, while keeping other inputs unchanged. The difference in production costs between the two simulations determines the cost of additional reserves to integrate wind, or the intra-hour wind integration cost. The remaining five simulations support the calculation of system balancing costs related to committing resources based on day-ahead forecasted wind generation and load. These simulations were run assuming operation in the 2015 calendar year, applying 2013 load and wind data. This calculation method combines the benefits of using actual system data with current forward price curves pertinent to calculating the costs for wind integration service on a forward basis, as well as the current resource portfolio.3s PacifiCorp resources used in the simulations are based upon the 2013 IRP Update resource portfolio.36 Determining system balancing costs requires a comparison between production costs with day- ahead information as inputs and production costs with actual information as inputs. 2013 was the most recent year with the availability of these two types of data. Day-ahead wind generation forecasts for all owned and contracted wind resources were collected from the Company's wind forecast service provider, DNV GL.37 For 2012 and2Ol3, DNV GL provided data sets for the historical day-ahead wind forecasts. The day-ahead load forecast was provided by the 3a P50 signifies the probability exceedance level for the annual wind production forecast; at P50 generation is expected to exceed the assumed generation levels half the time and to fall below the assumed generation levels half the time. 35 The Study uses the December 3l,2}l3 official forward price curve (OFPC). 36 The 2013 Integrated Resource Update report, filed with the state utility commissions on March 31,2014 is available for download from PacifiCorp's IRP Web page using the following hyperlink: http ://www.pac ifi corp. com/es/irp.html " This is the same service provider as used by the Company previously, Garrad Hassan. Ganad Hassan is now part ofDNV GL. t2t PecrrConp-2015 IRP APPENDX H - WIND INTEGRATIoN Company's load forecasting department. There are five PaR simulations to estimate daily system balancing wind integration costs, labeled as Simulations 3 through 7. In this phase of the analysis, PacifiCorp generation assets were committed consistent with a day-ahead forecast of wind and load, but dispatched against actual wind and load. To simulate this operational behavior, the five additional PaR simulations included the incremental reserves from Simulation 2 and the unit commitment states associated with simulating the portfolio with the day-ahead forecasts. Load system balancing costs capture the difference between committing resources based on a day-ahead load forecast and committing resources based on actual load, while keeping inputs for wind generation unchanged. Similarly, wind system balancing costs capture the difference between committing resources based on day-ahead wind generation forecasts and committing resources based on actual wind generation, while keeping inputs for load unchanged. Simulation 3 determines the resource commitment for load system balancing and Simulation 5 determines the resource commitment for wind system balancing. The difference in production costs between Simulations 4 and 6 is the load system balancing cost due to committing resources using imperfect foresight on load. The difference in production cost between Simulations 6 and 7 is the wind system balancing cost due to committing resources using imperfect foresight on wind generation. Table H.12 above is a revision from what was presented in the 2012 WIS. The revision was made to remove the impact of volume changes between day-ahead forecasts and actuals on production costs. Table H.13 lists the simulations performed in the 2012 WIS, which shows that wind system balancing costs were determined based on the change in production costs between Simulation 5 and Simulation 4. The wind system balancing costs are captured by committing resources based on a day-ahead forecast of wind generation, while operating the resources based on actual wind generation. However, between Simulation 4 and Simulation 5, the volume of wind generation is different. As a result, the production cost of Simulation 5 is impacted by changes in wind generation. Using the approach adopted in the 2014 WIS as discussed above isolates system balancing integration costs to changes unit commitment. 122 PACIFICORP_2OI5IRP APPENDIX H _ WIND INTEGRATION Table H.13 - Wind Integration Cost Simulations in PaR,2012 WIS Reculatlnr Melpin Resene Cost Rsns I 2015 20l5Inad Forecast Eryected Profile No None )2015 2015 Load Forecast Erpected Profile Yes None Renrlatins Marsin Cost = System Cost from PaR Simulation 2 less System Cost from PaR Simulation I Svstsm Bellncirc Cost Rrtm 3 2015 2013 Day-alrcad Forecast 2013 Day-ahead Forecast Yes None 4 2015 2013 Acnnl 2013 Day-alrcad Forecast Yes For l.oad 5 2015 2013 Actual 2013 Actual Yes For Load and Wind Load Sptem Bahncing Cost: Sptem Cost fom PaR simuhtbn 4 (which wes the urit con:rnirrrent fom Sinnrhtbn 3) less system cost from PaR sinurhtbn 3 Wind System Balancing Cost = System Cost fom PaR sinmhtbn 5 (whbh uses the urit cormnitrnerf from Sinmhtbn 4) less svstem cost from PaR sinmhtbn 4 Also different from the 2012 WIS, the regulating margin reserves are input to the PaR model on an hourly basis, after being reduced for the estimated benefits of participating in the EIM, as discussed in more detail below. Table H.l4 shows the intra-hour and inter-hour wind integration costs from the 2014 WIS. In the.2015 IRP process, the System Optimizer (SO) model uses the 2014 WIS results to develop a cost for wind generation services. Once candidate resource portfolios are developed using the SO model, the PaR model is used to evaluate the risk profiles of the portfolios in meeting load obligations, including incremental operating reserve needs. Therefore, when performing IRP risk analysis using PaR, specific operating reserve requirements consistent with this wind study are used. The Company performed several sensitivity scenarios to address recommendations from the TRC in its review of PacifiCorp's20t2 WIS. Each is discussed in turn below. Modeling Regulating Margin on a Monthly Basis As shown in Table H.10 and Table H.11, the component reserves and the total reserves are determined on a l0-minute interval basis. In the 2012 WIS, PacifiCorp calculated reserve requirements on a monthly basis by averaging the data for all l0-minute intervals in a month and Table II.14 - 2014 Wind Integration Costs, $Mwh Total Wind In 123 PacHConp-2015 IRP APPENDIX H - WTND INTEGRATIoN applying these monthly reserve requirements in PaR as a constant requirement in all hours during a month. The TRC recommended that the reserve requirements could be modeled on an hourly basis to reflect the timing differences of reserves. In calculating wind integration costs for the 2014 WIS, the PacifiCorp modeled hourly reserve requirements as recommended by the TRC. Table H.15 compares wind integration costs from the2012 WIS with wind integration costs from the 2014 WIS calculated using both monthly and hourly reserve requirements as inputs to the PaR model. Table H.15 - Comparison of Wind Integration Costs Calculated Using Monthly and Hourly Reserve Requirements as Inputs to PaR, ($lMWh) Compared to the 2012 WIS intra-hour reserve cost, the 2014 WIS intra-hour reserve cost is lower when reserves are modeled on a monthly basis in PaR. This is primarily due to the addition of a the Lake Side 2 combined-cycle plant, which can be used to cost effectively meet regulating margin requirements. Without Lake Side 2, the intra-hour reserye costs for the 2014 WIS Monthly Reserve sensitivity would increase from $1.66Artwh to $2.65/lr4Wh. As compared to the 2012 WIS, which reported wind integration costs using monthly reserve data, the increase in cost is primarily due to increases in the market price for electricity and natural gas. Table H.16 compares the natural gas and electricity price assumptions used in the 2012 WIS to those used in the 2014 WIS. Table H.16 - Average Natural Gas and Electricity Prices Used in the 2012 anil2014 Wind Integration Studies When modeling reserves on an hourly basis in PaR, the intra-hour reserve cost is higher than when modeling reserves on a monthly basis. This is due to more reserves being shifted from relatively lower-priced hours to relatively higher-priced hours. Figure H.7 shows the average profiles of wind regulating margin reserves from 2013. 124 PACIFICoRP_20I5 IRP APPENDD( H - WTND INTEGRATION Figure H.7 - Average Hourly Wind Reserves for 2013, MW =E 160 140 120 100 80 60 40 20 0 7 8 9 101112t3L4L5L6L7 18192021222324 Hour ft35l +West Separating Regulating and Following Reserves In its review of the 2012 WIS, the TRC recommended treating categories of reserves differently by separating the component reserves of regulating, following and ramping. That is, instead of modeling regulating margin as: Load Regutatingiz + Wind Regulatingiz + Load Foltowingiz + Wtnd Followtngt' - Lro I Ramp, The TRC recommendation requires calculating regulating reserves and following reserves using two separate calculations: Regutating Reserves = -Lls,and Following Reserves = I Ramp. Because regulating reserves are more restrictive than following reserves (fewer units can be used to meet regulating reserve requirements), the L1e adjustment is applied to the regulating reserve calculation. Ramp reserves can be met with similar types of resources as following reserves, and therefore, are combined with following reserves. The impact of separating the component reserves as outlined above is to increase the total reserve requirement required on PacifiCorp's system. Table H.l7 shows the total reserve requirement when the separately calculated regulating and following reserves are summed as compared to the total reserves combined using one RSS equation. The total reserve requirement, 125 PecnrCopp - 2015 IRP APPENDD( H - WIND INTEGRATIoN when calculated separately, is over 30o/o higher than the reserve requirement calculated from a single RSS equation. This is a significant increase in the amount of regulation reserves that is inconsistent with how the Company's resources are operated and dispatched. As a result, PacifiCorp did not evaluate this sensitivity in PaR. Table H.l1 - Total Load and Wind Monthly Reserves, Separating Regulating and Following Reserves (M!Y) Jan 238 400 Feb 212 363 Mar 219 357 Apr 240 422 May 192 400 Jun 183 462 Jul 219 427 Aug 220 428 Sep 210 392 Oct 153 335 Nov 30r 438 Dec 274 433 EIM is an energy balancing market that optimizes generator dispatch between PacifiCorp and the CAISO every five minutes via the existing real-time dispatch market functionality. PacifiCorp and the CAISO began a phased implementation of the EIM on October 1,2014, when EIM was activated to allow the systems that will operate the market to interact under realistic conditions, allowing PacifiCorp to submit load schedules and bid resources into the EIM and allowing the CAISO to use its automated system to generate dispatch signals for resources on PacifiCorp's control areas. The EIM is expected to be fully operational November 1,2014. Once EIM becomes fully operational, PacifiCorp must provide sufficient flexible reserve capacity to ensure it is not leaning on other participating balancing authorities in the EIM for reserves. The intent of the EIM is that each participant in the market has sufficient capacity to meet its needs absent the EIM, net of a CAISO calculated reserves diversity benefit. In this manner, PacifiCorp must hold the same amount of regulating reserve under the EIM as it did prior to the EIM, but for a calculated diversity benefit.'o Figure H.8 illustrates this process. 38 Under the EIM, base schedules are due 75 minutes prior to the hour of delivery. The base schedules can be adjusted at 55 minutes and 40 minutes prior to the delivery hour in response to CAISO sufftciency tests. This is consistent with pre-EIM scheduling practices, in which schedules are set 40 minutes prior to the delivery hour. 107 196 211 354 318 550 100 182 187 318 287 500 97 179 202 313 299 492 123 224 208 362 331 s86 84 205 180 348 264 553 70 240 179 393 249 633 88 80 206 391 294 572 90 88 206 388 296 576 100 71 188 36r 287 533 75 59 131 301 206 461 165 228 249 375 414 603 122 216 251 375 373 592 126 PecrrConp-2015 IRP APPENDIX H - WTND INTEGRATIoN Figure H.E - Energy Imbalance Market \Hcrr@np Dctcrminc Rcgulating Maryin Rcscrves .: : Brscd on WlS ... -- . Rcsults t \PrcrrEoRP Rcalic "Divcrsity 8cnefft' end RcflGGt Rcductlon ln Rcaulatiry Margln Rcscrvcs fr $ cotib.io tso "DiveEity Bcnc{it" The CAISO will calculate the diversity benefit by first calculating the reserve requirement for each individual EIM participant and then by comparing the sum of those requirements to the reserve requirement for the entire EIM area. The latter amount is expected to be less than the sum due to the portfolio diversification effect of load and variable energy resource (wind and solar) variations. The CAISO will then allocate the diversity benefit among all the EIM participants. Finally, PacifiCorp will reduce its regulating reserve requirement by its allocation of diversity benefit. In its 2013 report, Energy and Environmental Economics (E3) estimated the following benefits of the EIM system implementation:" - PacifiCorp could see a 19 to 103 MW reduction in regulating reserves, depending on the level of bi-directional transmission intertie made available to EIM; - Interregional dispatch savings: Five-minute dispatch efficiency will reduce "transactional friction" (e.9., transmission charges) and alleviate structural impediments currently preventing trade between the two systems; - Intraregional dispatch savings: PacifiCorp generators will dispatch more efficiently through the CAISO's automated system (nodal dispatch software), including benefits from more efficient transmission utilization; - Reduced flexibility reserves by aggregating the two systems' load, wind, and solar variability and forecast errors; - Reduced renewable energy curtailment by allowing BAAs to export or reduce imports of renewable generation when it would otherwise need to be curtailed. Based on the E3 study, the relationship between the benefit in reducing regulating reserve requirements and the transfer capability of the intertie is shown in Table H.18. @ Colibrnio ISO Dctcrmine Flcxiblc Rampln3 Rcqulrcmcnts fur PaclfiCorp and CAISO, Separatcly and Combined t 3e http://www.caiso.com/Documents/PacifiCorp-ISOEnersylmbalanceMarketBenefits.pdf 127 PACIFICoRP-2015 IRP APPENDIX H _ WIND INTEGRATIoN Given that the transfer capacity in this WIS is assumed to be approximately 330 MW, through owned and contracted rights, the reduction in regulating reserve is assumed to be approximately 65 MW. This benefit is applied to reduce the regulating margin on PacifiCorp's west BAA because the current connection between PacifiCorp and CAISO is limited to the west only. Table H.l9 summarizes the impact of estimated EIM regulating reserve benefits assuming monthly application of reserves in PaR to be comparable to how the 2012 WIS wind integration costs were calculated. The sensitivity shows that EIM regulating reserve benefits reduce wind integration costs by approximately $0.2 I /IvIWh. Table H.19 - Wind Integration Cost with and without EIM Benefit, $/MWh The 2014 WIS determines the additional reserve requirement, which is incremental to the mandated contingency reserve requirement, needed to maintain moment-to-moment system balancing between load and generation while integrating wind resources into PacifiCorp's system. The 2014 WIS also estimates the cost of holding these incremental reserves on its system. PacifiCorp implemented the same methodology developed in the 2012 WIS for calculating regulating reserves for its 2014 WIS, and implemented recommendations from the TRC to implement hourly reserve inputs when determining wind integration costs using PaR. Also consistent with TRC recommendations, PacifiCorp further incorporated regulation reserve benefits associated with EIM in its wind integration costs. Table H.20 compares the results of the 2014 WIS total reserves to those calculated in the 2012 WIS. 128 PacmrConp-2015 IRP AppsNolx H _ WIND INTEGRATION Table H.20 - Regulating Margin Requirements Calculated for PacifiCorp's System (MW) 20tt (2012 wrs) Load-Onlv Rezulatine Reserves 99 176 il9 394 Incremental Wind Reserves 50 126 9 185 Total Reserves 149 302 128 579 2012 Load-Onlv Rezulatine Reserves 95 186 ll9 400 Incremental Wind Reserves 7l 123 lt 206 Total Resenes 166 309 130 606 2013 (2013 wrs) Load-Onlv Reeulatine Reserves 119 203 ll9 441 Incremental Wind Reserves 51 123 t2 186 Total Reserves 169 326 131 626 The anticipated implementation of EIM with the CAISO is expected to reduce PacifiCorp's reserve requirements due to the diversification of resource portfolios between the two entities. PacifiCorp estimated the benefit of EIM regulating reserve benefits based on a study from E3. The assumed benefits reduce regulating reserves in PacifiCorp's west BAA by approximately 65 MW from the regulating reserves shown in the table above, which lowers wind integration costs by approximately $0.2 I /IvIWh. Two categories of wind integration costs are estimated using the Planning and Risk (PaR) model: one for meeting intra-hour reserve requirements, and one for inter-hour system balancing. Table H.2l compares 2014 wind integration costs, inclusive of estimated EIM benefits, to those published in the 2012 WIS. Table H.2l - 2014 WIS Wind Integration Costs as Compared,to2012 WIS, $/Mwh The 2014 WIS results are applied to the 2015 IRP portfolio development process as a cost for wind generation resources. Once candidate resource portfolios are developed using the SO model, the PaR model is used to evaluate portfolio risks. After resource portfolios are developed using the SO model, the PaR model is used to evaluate the risk profiles of the portfolios in meeting load obligations, including incremental operating reserve needs. Therefore, when performing IRP risk analysis using PaR, specific operating reserve requirements consistent with the2014 WIS are used. 129 Date: December 22,20L4 To: PacifiCorp From: 2014 Wind lntegration Study Technical Review Committee (TRC) Subject: PacifiCorp 2014 Wind lntegration Study Technical Memo Background The purpose of the PacifiCorp 2072 wind integration study as identified by Pacificorp in the lntroduction to the 2015 lRP, Appendix H - Draft Wind lntegration Study, is to estimate the operating reserves required to both maintain PacifiCorp's system reliability and comply with North American Electric Reliability Corporation (NERC) reliability standards. PacifiCorp must provide sufficient operating reserves to meet NERC's balancing authority area control error limit (BAL-001-2) at all times, incremental to contingency reserves, which PacifiCorp maintains to comply with NERC standard BAL-002-WECC-2.I'2 Apart from disturbance events that are addressed through contingency reserves, these incremental operating reserves are necessary to maintain area control error3 IACE), due to sources outside direct operator control including intra-hour changes in load demand and wind generation, within required parameters. The wind integration study estimates the operating reserve volume required to manage load and wind generation variation in PacifiCorp's Balancing Authority Areas (BAAs) and estimates the incremental cost of these operating reserves. PacifiCorp currently serves 1.8 million customers across 136,000 square miles in six western states. According to a company fact sheet available at http://www.pacificorp.com/content/dam/pacificorp/doc/About Us/Companv Overview/PC-FactSheet- Final Web.pdf. PacifiCorp's generating plants have a net capacity of 10,595 MW, including about 1,900 t NERC Standard BAL-001-2: http://www.nerc.com/files/BAL-0O1-2.odf ' NERC Standard BAL-OO2-WECC-2 (http://www.nerc.com/files/BAL-002-WECC-2.pdf), which became effective October t,20L4, replaced NERC Standard BAL-STD-O02, which was in effect at the time of this study.,.?reaControlErro/,isdefinedintheNERCglossaryhere: terms/elossarv of terms.pdf MW of owned and contracted wind capacity, which provides approximately 8o/o of PacifiCorp's annual energy. PacifiCorp operates two BAAs in WECC, referenced as PACE (PacifiCorp East) and PACW (PacifiCorp West). The BAAs are interconnected by a limited amount of transmission, and the two BAAs are operated independently at the present time, so wind generation in each BAA is balanced independently.4 PacifiCorp has experienced continued wind growth in each BAA, and has been requested to update its wind integration study as part of its lRP. The total amount of wind capacity in PacifiCorp's BAAs, which was included in the 2014 wind integration study, was 2,544 MW. TRC Process The Utility Variable-Generation lntegration Group (UVIG) has encouraged the formation of a Technical Review Committee (TRC) to offer constructive input and feedback on wind integration studies conducted by industry partners for over 10 years. The TRC is generally formed from a group of people who have some knowledge and expertise in these types of studies, can bring insights gained in previous work, have an interest in seeing the studies conducted using the best available data and methods, and who will stay actively engaged throughout the process. Over time, the UVIG has developed a set of principles which is used to guide the work of the TRC. A modified version of these principles was used in the conduct of this study, and the same version was used for the conduct ofthe TRC process for the 2012 wind integration study. A copy is included as an attachment to this memo. The composition of the TRC for the 2014 PacifiCorp study was as follows: o Andrea Coon - Director, Western Renewable Energy Generation lnformation System (WREGIS) for the Western Electricity Coordinating Council (WECC) o Matt Hunsaker - Manager, Operations for the Western Electricity Coordinating Council (wEcc) o Michael Milligan - Principal Researcher for the Transmission and Grid lntegration Team at the National Renewable Energy Laboratory (NREL) o J. Charles Smith - Executive Director, Utility Variable-Generation lntegration Group (UVIG) o Robert Zavadil - Executive Vice President of Power Systems Consulting, EnerNex The TRC was provided with a study presentation in July of 20L4, and met by teleconference on 2 occasions during the course of the study, which was completed in November 2014. PacifiCorp provided presentations on the status and results of the work on the teleconferences, with periodic updates a PacifiCorp and the CAISO began operating an energy imbalance market (ElM) on Oct. L,2OL4, which will likely make wind integration somewhat easier. With the ElM, there would seem to be more impetus for this policy to be reviewed and potentially revised going fonvard. The TRC recommends that this topic be explored in future work. during the course of the study, and engaged with the TRC in a robust discussion throughout the work. The teleconferences were followed up with further clarifications and responses to requests for additional information. While the conclusions appear justified by the results of the study, the TRC review should not be interpreted as a substitute for the usual PUC review process. lntroduction The Company should be acknowledged for the diligent efforts it made in implementing the recommendations by the TRC from the 2012 wind integration study in the 2014 study, as summarized in Table H.1. For example, the company modeled the reserve requirements on an hourly basis in the production cost model, rather than on a monthly average basis; the regulating margin reserve volumes accounted for estimated benefits from PacifiCorp's participation in the energy imbalance market (ElM) with the California lndependent System Operator (CAISO); and a discussion on the selection of a 99.7% exceedance level when calculating regulation reserve needs was provided, including a description of how the WIS results inform the amount of regulation reseryes planned for operations. Sensitivity studies were performed, including the modeling of the regulating reserves on a monthly basis, and demonstrating the impact of separating the reserves into different categories. The 2014 wind integration study report thoroughly documents the company's analysis. As pointed out in the report, there is a small but meaningful difference in the integration costs between the 2012 study and the 2014 study. The 2012 value of S2.55/MWh of wind generation, using monthly reserves in PaR, is slightly less than the 2014 value of 53.06/MWh, using hourly reserves in the Planning and Risk (PaR) production cost model, with the major difference attributed to the modest increase in the cost of electricity and natural gas. When modeling reserves on an hourly basis in PaR, the intra-hour reserve cost is higher than when modeling reserves on a monthly basis. This is due to more reserves being shifted from relatively lower-priced hours to relatively higher-priced hours. Analytical Methodology o The first paragraph on p. 24 of the revised Appendix H, entitled "Application of Regulating Margin Reserves in Operations" is a criticalaspect of this study, albeit a little late to the interactions between Pacificorp and the TRC. ln effect, it means that the results of this study are and have been applied in operations, which is very unique in the universe of wind integration analysis since nearly all other studies are forward looking and utilize synthesized data and other assumptions. While this paragraph sufficiently addresses the points raised by the TRC in the late summer of 20L4, it should receive more prominence in the report. A comparison of the interaction between the 2012 study methodology and PacifiCorp operations with the 2014 study methodology and Pacificorp operations should be included at the front of the document. Assumptions r The assumptions generally seem reasonable. PAC does a good job of laying out the process they use for the modeling and analysis. They have also provided discussion of the previous suggestions (from the 2012) study made by the TRC. o The report addresses the issue of the 99.7o/o coverage of variability, and says that the operators are expected to have sufficient reserves to cover all variability all of the time. lt would be interesting to contrast the company's policy of ensuring 100% reserve compliance with actual system performance. ln the November TRC call there was some helpful discussion on this issue. One item discussed was that using99.7% provides some margin of error in case a lower value, such as 95%, is used in the study but insufficient if the actual variability of wind/load were to increase. lt would be nice to see this discussion reflected in the report, which would provide some additionaljustification for the 99.7 percentile. The reason this point is raised is to magnify the point that PAC makes in the report; that there is a tradeoff between economics and reliability. Holding the system to an extremely high effective CPS performance will be somewhat costly, and it is not clear what impact this is having on wind integration costs. o The use of actual historical wind production data is excellent, and something that many studies are unable to do. This means that the PAC study is somewhat unique and PAC is to be commended for doing this work. At the same time, the report provides some illumination on the difficulties in using actual data, because data recovery rates can compromise the time series. PAC has done a good job in analyzing and correcting these inevitable data gaps, and this should not have a significant impact on the study results. Results o Table H.15 documents a comparison of the monthly versus hourly reserve modeling, and shows that a constant monthly reserve is less costly than reserves modeled on an hourly basis. The explanation provided is useful, but may leave out some factors such as non-linearity in reserve supply curve. ln addition, the shifting of reserves from lower price hours to higher price hours only seems to apply to the East area, as the West area exhibits the opposite characteristic. Discussion and Conclusions o Table H.17 shows that the total reserves increase with consideration of regulation and following separately. lt should be noted that while the arithmetic sum of the reserves does increase, it would not necessarily lead to higher costs as some of the following reserve could be obtained from non-spinning and quick-start resources which cost little to have on standby for such purpose. o Based on the information provided by PacifiCorp, the methodology used in the wind integration study appears to be reasonable. Based on the draft study report, the findings and conclusions appear sound. The findings appear to be useful to inform the lntegrated Resource Planning process. Recommendations for Future Work Wind lntegration modeling presented is unique in how it is integrated with the operating process at PacifiCorp. There are some sensitivity studies which could be done to shed additional light on the results and provide some useful insights: o Future work should explore balancing area cooperation between PACE and PACW under the EIM framework. o Regulating margin implies reserve capacity available on very short notice (ten minute or less). The ramping and following reserve categories do not all require fast response. Future sensitivity studies could be done to compare the results from PaR to use of the RSS formula. o lt might be usefulto perform some additional sensitivities on natural gas price. For example, integration costs would be expected to increase with gas prices, yet at higher gas prices PAC would be getting a larger benefit from wind energy. o A sensitivity analysis with carbon tax assumptions could also provide some useful insight and results. Concurrence provided by: Andrea Coon - Director of WREGIS, WECC Matt Hunsaker - Manager, Operations, WECC Michael Milligan - Principal Researcher, Transmission and Grid lntegration Team, NREL J. Charles Smith - Executive Director, UVIG Robert Zavadil - Executive Vice President, EnerNex