HomeMy WebLinkAbout20071005Comments.pdfPeter J. Richardson ISB 3195
RICHARDSON & O'LEARY PLLC
99 East State Street
PO Box 1849
Eagle, Idaho 83616
Telephone: (208) 938-7900
Fax: (208) 938-7904
peter~richrdsonandoleary. com
Attorneys for Exergy Development Group of Idaho LLC
REC;::
!\!.. '"
LamOC
' -~ '
I'; l:
. ,'
no iQ,:~jP~H?~\~5('
' .
,,1 IC;) C'Jt"II,II'h.::d,..J"
,..
BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE PETITION OF
ROCKY MOUNTAIN POWER FOR AN
ORDER REVISING CERTAIN OBLIGATIONS)
TO ENTER INTO CONTRACTS TO
PURCHASE ENERGY GENERA TED BY
WIND-POWERED SMALL POWER
GENERATION QUALIFYING FACILITIES
CASE NO. PAC-07-
EXERGY DEVELOPMENT GROUP
OF IDAHO LLC'S COMMENTS
COMES NOW Exergy Development Group ofldaho LLC ("Exergy ) by and through
its attorney of record, Peter J. Richardson, and pursuant to that notice issued by the Idaho Public
Utilities Commission ("Commission ) on August 22 2007, as amended by September 19 2007
and hereby provides its Comments in response to Rocky Mountain Power s ("Rocky Mountain
or the "Company ) above captioned Petition. In support hereof Exergy says as follows:
SUMMARY OF EXERGY'S POSITION
Modified procedure should be utilized in this docket for the sole purpose of denying
Rocky Mountain s Petition. Absent outright denial, Exergy opposes the use of modified
procedure to prosecute this highly complex and technical case.
Exergy Development Group ofIdaho LLC's Comments PAC-O7-
BACKGROUND AND STANDARD OF REVIEW
This Commission s rules require that a decision to proceed under modified procedure be
based upon a finding that "the public interest may not require a hearing to consider the issues
presented." IPUCRules of Procedure IDAPA 31.01.01.201. (herein "Rule ) The Commission
decision must be based on the record before it as detailed in Rule 281 which provides that:
The Commission bases its decisions and issues its orders on the hearing record
(excluding exhibits denied admission), the Commissioners' record and items official
noted.
The "Commissioner s record" consists of "all pleadings, orders, notices, briefs, proposed orders
and position papers." Rule 284.01 The Commissioner s record also includes the "complete
hearing record of transcripts and exhibits." Rule 285.
The Commission is a fact finding, quasi-legislative body authorized to investigate and
determine issues presented by a utility s petition for increased (changed) rates. The
Commission s findings must be supported by competent and substantial evidence. Application
ofPacifiic Tel. Tel. Co" 71 Idaho 476, 480, 233 P.2d 1024 (1951).
The substantive record in this docket, as it relates to wind integration costs, consists
solelyl of Rocky Mountain s Petition and a three page attachment from its 2004 IRP. The
attachment, a document prepared by Rocky Mountain, is entitled "An Excerpt Taken From
PacifiCorp - 2004 IRP Appendix J - Renewable Generation Assumptions" (herein "IRP
1 Yesterday s filings in this docket were not made in time for Exergy to respond by the
close of comment according to the Notice. Exergy will respond according to Commission
direction.
Exergy DevelopmentGroup ofIdaho LLC's Comments PAC-O7-
Excerpt") The ultimate conclusion of the IRP Excerpt is that Rocky Mountain will experience
high costs for which it is not compensated in order to integrate wind into its electrical system.
In its Petition, Rocky Mountain seeks a reduction in the Commission approved avoided
cost rates by $5.04 to account for wind integration costs. Rocky Mountain s proposed wind
integration cost adjustment is set based on the fiction that there are 1 000 megawatts of installed
wind capacity on its system. IRP Excerpt at p. 12?
For the reasons stated below, Exergy asserts that Rocky Mountain s Petition is not
supported by substantial and competent evidence and that a full hearing must be held by this
Commission prior to issuing its order declaring what Rocky Mountain s wind integration rate is
or indeed if Rocky Mountain has a wind integration cost in the first place.
III
ROCKY MOUNTAIN'S PETITION SHOULD BE DENIED OUTRIGHT
Modified procedure in this docket is appropriate only if the outcome is the denial of
Rocky Mountain s Petition.
The gist of Rocky Mountain s Petition is that large amounts of wind generation on its
system will result in high costs to integrate that intermittent resource in a reliable manner.
Rocky Mountain has not averred that it HAS a large amount of wind connected to its system. It
avers that it MAY have a large amount of wind at some time in the future. It has not averred that
it currently is experiencing any problems with integrating wind into its system at this time.
Indeed, Rocky Mountain s proposed Wind Integration Rate is based on the assumption that it has
000 megawatts of installed wind. In reality it has less than 135 megawatts3 of installed wind.
This is the flip side of retroactive ratemaking. Rocky Mountain is asking that today s rates be set
2 The pagination of the IRP Excerpt is apparently from the original IRP.
3 Page 24 Appendix A PacifiCorp 2007 IRP. Attachment B.
Exergy Development Group ofIdaho LLC's Comments PAC-O7-
based upon contingent events that mayor may not happen at some point in the future. Given that
Idaho s IOUs have (a) successfully stymied all new wind development in Idaho for over two
years and (b) that it only has 135 megawatts on its system today; its assertion that it must
immediately impose a Wind Integration Rate based on one thousand megawatts of wind on its
system is simply not credible. The Petition should be denied.
Setting rates based on assumptions that are known to be false would violate the most
basic of ratemaking tenants. To that end, setting rates to be effective immediately based on a
contingent that has not occurred, may not occur and if it does occur, it may not do so for many
years is simply reckless and illegal. Idaho Code Section 61-622 requires a showing that "any
rate" be "justified". Setting a rate to recover a non-existent cost is unjustifiable.
An alternative to denying Rocky Mountain s Petition outright, would be to implement a
system by which the Wind Integration Rate varies as the company s wind integration costs vary
(both up and down). It is widely anticipated that integration costs may go up as penetration
levels go up. On the other hand it is also widely anticipated that wind integration costs will go
down as utilities gain experience with this renewable resource. Setting a fixed rate today based
on an assumed penetration rate of one thousand megawatts is, candidly, a blunt, unsophisticated
and inaccurate attempt to solve for a problem that doesn t even exist at this time, and indeed
may never exist.
If the Commission chooses to proceed with a wind integration rate that actually is an
attempt to accurately reflect wind integration costs at the time they occur, it would have to set a
variable wind integration rate. Such a rate would need to have a ceiling in order to provide
certainty to the developer that the project can be financed without the potential for an unlimited
and unknown reduction in operating revenues. That ceiling would presumably be the expected
Exergy DevelopmentGroup ofIdaho LLC's Comments PAC-O7-
wind integration rate at an assumed build-out of wind projects on the system. The ceiling would
not be a target, but rather a cap above which the wind integration cost rate would not exceed.
course, working out the details of such a program would take a process and require a record be
developed before the Commission for review and approval. Modified procedure is not the
appropriate vehicle for developing such a record.
MODIFIED PROCEDURE IS INAPPROPRIATE
Rocky Mountain filed its Petition in this matter on April 23, 2007, as a result of failing to
reach a settlement of the issues raised in Idaho Power s wind integration suspension proceeding
in Docket No. IPC-05-22 which was opened back in June of2005 and in which Rocky
Mountain participated through its parent, PacifiCorp. In that docket, in which PacifiCorp
participated and supported Idaho Power s request that the Commission initiate a "suspension of
the company s obligation under. . . PURPA to enter into new contracts to purchase energy
generated by qualifying wind-powered small power production facilities." Order No. 29872 at p.
1. (the "Suspension Docket") Technically, this Commission did not suspend the Company
obligations under PURP A. Rather, it eliminated the opportunity for any wind QF larger than 100
kw to entitlement to the Commission s published avoided cost rates. The real-world effect of
the Suspension Docket was to excuse the company s obligations under PURPA to offer its
avoided cost rates to qualifying wind power small power production facilities.
The Commission observed that:
Based on the record established in this case the Commission finds reason to believe that
wind generation presents operational integration costs to a utility different from other
PURP A qualified resources. We find that the unique supply characteristics of wind
generation and the related integration costs provide a basis for adjustment to the
published avoided cost rates, a calculated figure that may be different for each regulated
utility. The procedure to determine the appropriate amount of adjustment, we find, and
the identification of what studies, if any, need to be performed to provide such a number
Exergy Development Group ofIdaho LLC's Comments PAC-O7-
is a matter appropriate for further proceedings. The record reflects that a wind
integration study, if required, may take six months to develop. Rocky Mountain has
asked for a suspension period from six to nine months.
Order No. 39839 at p. 8. Emphasis provided.
Twenty six months later we are asked to comment on whether the wind integration study filed in
this docket accomplishes the goals established for all three IOUs in IPC-05-22. The
intervening two years, during which the wind industry in Idaho has been effectively frozen, have
seen construction costs skyrocket and have cost Idaho many millions of dollars in lost economic
benefits and will cost Idaho many untold millions into the future due to the lost opportunities
suffered by the wind industry in this state. With that said, it is nevertheless critical that if this
Commission decides to impose a wind integration rate on wind powered QFs, that it get it right
the first time. That is one reason why Exergy opposes the use of modified procedure in this
matter for all outcomes except for a denial of the petition.
In its final report to the Commission4 regarding progress in working with interested
parties to reach a consensus settlement of its wind integration costs, Idaho Power provided a list
of individuals and firms who participated in its wind integration workshops. The participants
included Rocky Mountain s parent, PacifiCorp, and the following individuals, companies, state
agencies, federal agencies, advocate groups, wind developers and public utilities:
Advocates for the West A vistaBatt & Fisher B.R.E. Inc.Cassia Wind Elmore County Agribusiness
Energy Vision Exergy
Hanson, John Idaho National Laboratory
Idaho Public Utilities CommissionIdaho Wind Idaho Wind Farms
IDWR-Energy Division Magic Wind
McDevitt & Miller NW Energy CoalitionPacifiCorp Paine Hamblen
4 IPC-O5-22 filed January 31 , 2006.
Exergy Development Group ofIdaho LLC's Comments PAC-O7-
Renaissance Engineering
Richardson & O'Leary
Snake River Alliance
Windland
Wirt, John
Renewable Northwest Project
Ridgeline Energy
Windadvantage
Windlogics
After five workshops and settlement conferences and with the combined efforts of the above list
of experts no consensus was reached. Rocky Mountain s current filing is not the result of a
consensus - either as to methodology or its ultimate conclusions. The wind development
industry is opposed to Rocky Mountain s filing because the industry does not believe it
accurately reflects Rocky Mountain s integration costs.
Rocky Mountain s only evidence in the record as to the accuracy of its wind integration
costs are three pages taken from its 2004 IRP which this Commission has never approved for
ratemaking purposes. Indeed, the Commission s only official response to the filing of Rocky
Mountain IRP was to "acknowledge the 2004 IRP". Petition at p. 4. A three page excerpt
from a document that was merely "acknowledged" for filing cannot be reasonably asserted to
rise to the level of substantial competent evidence upon which rates are set.
For all ofthe foregoing, Exergy respectfully requests that Rocky Mountain s Petition be
denied or in the alternative that a full evidentiary hearing be conducted to investigate the true
level of wind integration costs for the Rocky Mountain system.
Respectfully submitted this 5th day of October 2007.
RICHARDSON & O'LEARY PLLC
Peter J. Richardson
Attorneys for Exergy Development Group
of Idaho, LLC
Exergy DevelopmentGroup ofIdaho LLC's Comments PAC-O7-
ATTACHMENT A
Exergy Development Group ofIdaho LLC's Comments PAC-O7-
Re
c
e
n
t
S
t
u
d
i
e
s
o
f
Wi
n
d
I
n
t
e
g
r
a
t
i
o
n
C
o
s
t
s
$/
M
W
h
Lo
a
d
Un
i
t
Pe
n
e
t
r
a
t
i
o
n
Re
g
u
l
a
t
i
o
n
Fo
l
l
o
w
i
n
g
Co
m
m
i
t
m
Ga
s
To
t
a
l
Da
t
e
St
u
d
y
Co
s
t
s
Co
s
t
en
t
C
o
s
t
Su
p
p
l
y
Im
p
a
c
t
So
u
r
c
e
20
0
3
Xc
e
l
-
UW
I
G
$0
.
$0
.
4
1
$1
.
4
4
$1
.
DO
E
,
N
E
R
L
20
0
3
We
E
n
e
r
g
i
e
s
$1
,
$0
,
$0
,
$1
,
DO
E
,
N
E
R
L
20
0
3
We
E
n
e
r
a
i
e
s
29
.
$1
.
$0
.
$1
,
$2
,
DO
E
,
N
E
R
L
20
0
4
Xc
e
l
-
MN
D
O
C
15
.
$0
,
$4
,
$4
.
DO
E
,
N
E
R
L
20
0
4
VT
T
-
Sc
a
n
d
i
n
a
v
i
a
10
,
$1
,
RN
P
20
0
4
VT
T
-
Sc
a
n
d
i
n
a
v
i
a
20
.
$2
.
RN
P
20
0
5
Pa
c
i
f
i
C
o
r
p
20
.
$0
.
$1
,
$3
.
$4
.
DO
E
,
N
E
R
L
20
0
5
Pu
Q
e
t
S
o
u
n
d
10
,
$4
.
RN
P
20
0
6
CA
R
P
S
$0
.
4
5
$0
.
4
5
DO
E
,
N
E
R
L
20
0
6
Xc
e
l
-
PS
C
o
10
.
$0
.
$2
,
$1
,
$3
,
DO
E
,
N
E
R
L
20
0
6
Xc
e
l
-
PS
C
o
15
,
$0
,
$3
.
$1
.
4
5
$4
.
DO
E
,
N
E
R
L
20
0
6
MN
-
MI
S
O
$4
.
4
1
DO
E
,
N
E
R
L
20
0
6
MN
/
M
N
D
O
C
20
,
$0
,
$2
,
$2
.
Re
n
e
w
a
b
l
e
E
n
e
r
Q
V
C
o
n
s
u
l
t
i
n
g
S
e
r
v
i
c
e
s
,
N
R
E
L
20
0
6
MN
/
M
N
D
O
C
34
,
$0
.
$4
,
$4
.
4
1
Re
n
e
w
a
b
l
e
E
n
e
r
g
y
C
o
n
s
u
l
t
i
n
g
S
e
r
v
i
c
e
s
,
N
R
E
L
20
0
7
GE
/
P
i
e
r
/
C
a
I
A
P
20
.
$0
,
$0
.
NR
E
L
BP
A
l
H
i
r
s
t
$0
.
$1
.
4
0
$1
.
Re
n
e
w
a
b
l
e
E
n
e
r
g
y
C
o
n
s
u
l
t
i
n
g
S
e
r
v
i
c
e
s
,
N
R
E
L
New Studies Find
That Integrating Wind
into Power Systems
Is Manageable, But
Not Costless
Table 6, Key Results from Major Wind Integration Studies Completed 2003-2006
Date Study
2003 Xcel-UWIG
2003 We Energies
2003 We Energies
2004 Xcel-MNDOC
2005 PacifiCorp
20()6 CA RPS (multi-year)
2006 Xcel-PSCo
2006 Xcel-PSCo
2006 MN-MISO 20%
During the past several years
there has been a considerable
amount of analysis on the poten-
tial impacts of wind energy on
power systems, typically respond-
ing to concerns about whether the
electrical grid can accommodate
significant new wind additions,
and at what cost. The sophistica-
tion of these studies has increased
year averagedramatically In recent years,
Source: Nanonal Renewable Energy Laboratory.resu Ing In a e er accoun Ing 0
wind's impacts and costs (recall thatthese integration costs were
not included in the busbar wind power prices presented earlier),
Table 6 provides a selective listing of results from major wind
integration studies completed from 2003 through 2006, Because
methods vary and a consistent set of operational impacts has not
been included in each study, results from the different analyses are
not perfectly comparable, Nonetheless, the key findings of two
major new studies completed in 2006 in Colorado and Minnesota
are broadly consistent with those in earlier work, and (at a mini-
mum) show that wind integration costs are generally approximately
$5/MWh, or less, for wind capacity penetrations30 up to about 15%
of the local/regional peak load in which the wind power is being
delivered.31 Regulation and load-following impacts are generally
found to be small, whereas the impacts of wind on unit commit-
ment are more significant,
Wind Cost ($/MWh)
Capacity
Regulation Load Unit Gas TOTALPenetrationFollowingCommitmentSupply
1.44
29%
15%
20%
0.45*trace 0.45
10%
15%1.45
31%4.41**
mgh~t o~r 3feM evm~wn period
Transmission Is an Increasingly
Significant Barrier to Wind , but Solutions
Are Emerging
Relatively little investment has been made in new transmission
over the past 15 to 20 years, and in recent years it has become clear
that lack of transmission access and investment are major barriers
to wind development in the U.s, New transmission facilities are
particularly important for wind resource development because
of wind's locational dependence and distance from load centers,
In addition, there is a mismatch between the short lead times for
developing wind projects and the lengthier time often needed to
develop new transmission lines, Furthermore, wind's relatively low
capacity factor can lead to underutilization of new transmission
lines that are intended to only serve wind, The question of "who
pays?"for new transmission is also of critical importance to wind
developers and investors, Transmission rate pancaking, charges
imposed for inaccurate scheduling,and interconnection queuing
procedures have also sometimes been identified as impediments
to wind capacity expansion.
A number of developments occurred in 2006 that promise to
help ease some of these barriers over time, The U.s, DOE issued a
national transmission congestion study that designated southern
California and the mid-Atlantic coastal area from New York City to
northern Virginia as "critical congestion areas," Under the Energy
Policy Act of 2005 (EPAct 2005), the u.s. DOE can nominate National
Interest ElectricTransmission Corridors, and the Federal Energy
Regulatory Commission (FERC) can approve potential new transmis-
sion facilities in these corridors if states do not act within one year
or do not have the authority to act, among other conditions.
Separately, FERC issued a rule allowing additional profit incentives
for transmission owners on a case-by-case basis, also as required
by EPAct 2005, and thereby potentially encouraging greater
transmission investment,
In the West, the Western Governors Association adopted a
policy resolution through its Clean and Diversified Energy Advisory
Committee that included a goal of 30,000 MW of clean energy by
2015, with potentially significant contributions from wind power,
The recommendations ofthis committee to advance wind included
30 Wind penetration on a capacity basis (defined as nameplate wind capacity serving a region divided by that region s peak electricity demand) is frequentlyused in integration studies. For a given amount of wind capacity, penetration on a capacity basis is typically higher than the comparable wind penetration inenergy terms.
31 The recently completed study in Minnesota found that a 25% wind penetration within the state, based on energy production (31 % based on capacity), wouldcost $4.41/MWh or less. This low cost at such a high penetration rate is caused, in part, by the extensive interactions with the Midwest Independent SystemOperator (MISQ) markets, The low cost found in the California study is partly a reflection of the limited number of cost factors that were considered in theanalysis.
32 A number of additional wind integration analyses are planned for 2007, including a study of even-higher wind power penetrations in Colorado, thecompletion of the California Intermittency Analysis Project, andfurther work in the Pacific Northwest. Studies evaluating wind integration in the Southwest,and perhaps throughout the West, are also in the early planning stage.
33 The U.s. DOE has since issued draft National Interest ElectricTransmission Corridor designations for the two regions identified above and, as of this writing, isreceiving comments on this draft designation.
Annual Report on U,S. Wind Power Installation, Cost, and Performance Trends: 2006
...
.
.
A
n
a
t
i
o
n
a
l
l
a
b
o
r
a
t
o
r
y
of
th
e
U
.
S.
D
e
p
a
r
t
m
e
n
t
of
En
e
r
g
y
+..
.
Of
f
i
c
e
of
En
e
r
g
y
E
f
f
i
c
i
e
n
c
y
Re
n
e
w
a
b
l
e
E
n
e
r
g
y
-l
.
~1
'
5
!
.
Na
t
i
o
n
a
l
R
e
n
e
w
a
b
l
e
E
n
e
r
g
y
L
a
b
o
r
a
t
o
r
y
In
n
o
v
a
t
i
o
n
f
o
r
O
u
r
E
n
e
r
g
y
F
u
t
u
r
e
WE
C
C
Op
e
r
a
t
i
n
g
Im
p
a
c
t
s
Wi
n
d
P
o
w
e
r
i
n
g
Am
e
r
i
c
a
Su
m
m
i
t
Ju
n
e
6
,
20
0
7
Co
m
pa
r
i
s
o
n
o
f
C
o
s
t
-
Ba
s
e
d
S.
Op
e
r
a
t
i
o
n
a
l
I
m
p
a
c
t
St
u
d
i
e
s
Da
t
e
St
u
d
y
Wi
n
d
Re
g
u
l
a
-
Lo
a
d
Un
i
t
Ga
s
To
t
a
l
Ca
p
a
c
i
t
y
,
t
i
o
n
C
o
s
t
Fo
l
l
o
w
i
n
g
Co
m
m
i
t
-
Su
p
p
l
y
Op
e
r
a
t
i
n
g
Pe
n
e
t
r
a
-
($
/
M
W
h
)
Co
s
t
me
n
t
C
o
s
t
Co
s
t
Co
s
t
ti
o
n
(
%
)
($
/
M
W
h
)
($
/
M
W
h
)
($
/
M
W
h
)
Im
p
a
c
t
($
/
M
W
h
)
Ma
y
Xc
e
l
-
UW
I
G
0.
4
1
1.
4
4
Se
p
Xc
e
l
-
MN
D
O
C
Ju
n
e
CA
R
P
S
M
u
l
t
i
-
0.
4
5
*
tr
a
c
e
0.
4
5
ye
a
r
Fe
b
GE
/
P
i
e
r
/
C
A
I
A
P
tr
a
c
e
**
*
69
*
*
*
Ju
n
e
We
E
n
e
r
g
i
e
s
Ju
n
e
"
to
F: E C :
; !' :
::Efc.. 0'1 -
~\\\\I"lb
ZOul FEE I '2 :\1 j 10: ! 8
February 9, 2007 IU,\d.:j !\.:ULlC
UTlLr1'l:::) COL::,13SIG.
Renew~ Northwest Project
Jean D. Jewell, Secretary
Idaho Public Utilities Commission
472 West Washington Street
P. O. Box 83720
Boise, ill 83720-0074
Via email
Re: Operational Impacts ofIntegrating Wind Generation into Idaho Power's
Existing Resource Portfolio
Dear Ms. Jewell:
We appreciate the time and effort Idaho Power Company expended in
preparing their study Operation Impacts of Integrating Wind Generation into
Idaho Power s Existing Resource Portfolio (Study). In addition, Idaho Power
Company s analysts have been generous in sharing their intermediate results
and discussing their methodology with the Northwest Wind Integration Action
Plan (NWIAP) Peer Review Committee of which we are participants.
Unfortunately, due to perceived urgency felt by Idaho Power, the Study was
filed with the Idaho Commission prior to completing the NWIAP peer review
process. Taking extra time would allow parties on the Peer Review Committee
to have confidence in the results.
We believe this report is premature and we urge the Commission not to accept
it until the peer review process is complete. We also feel it is critical not to
base any other decisions, such as those proposed in Idaho s filing on PURPA
rules, on the study results until the report has been fully vetted. Allowing
Idaho Power extra time, and extra funding for their consultant if needed, is
important to this process. We also hope the Commission will encourage Idaho
Power to continue to share complete details of their wind data and analysis
methodology with regional stakeholders.
The timing was particularly unfortunate because the peer review group
identified some areas of concern in the calculations and methodology that had
the effect of systematically overestimating the reserve requirements. The peer
review committee wished to investigate further, Some of the concerns
identified include:
Inflated Market Price Data. We appreciate that Idaho Power was
interested in understanding the differences in system operations under low
average, and high water years. However, the market prices that corresponded
to the average water year are inflated because of the 2000-2001 energy crisis.
These high prices result in integration costs for those years that are
unreasonably high.
Attachment
Recent Wind Integration Studies Summary
c:; ,c; '
,:".
C-;; -J:"/ ,
,~'!;;
:::or: C:
~;:
~::~:u
! ';/'c i~'!h)
2005
Mar 2005
May 2003
Sep 2004
Jun 2003
Jun 2003
Apr 2006
Apr 2006
Nov 2006
Nov 2006
Dec 2004
Dee 2004
PacifiCorp
puget Sound Energy
Xcel-UWIG
Xcel-MNDOC
WE Energies
WE Energies
Xcel-PSCo
Xcel-PSCo
Enernex- MN
Enernex- MN
VTT - Scandinavia
VTT - Scandinavia
3;5
15*
25*
10*
20*
1.85
1.9
4.41
1. 29**
58**
Notes
*Penetration based on MWh generation / MWh load
**Euros/MWh converted to dollars (g) 1.29 Euro/dollar
Sources:
Grid Impacts of Wind Power Variability: Recent
Assessments froma Variety of Utilities in the United
States," Parsons/Milligan et ai, NREL, July 2006
Final Report- Minnesota Wind Integration Study,
Minnesota Public Utility Commission, November 30,
2006
The Impact of Large Scale Wind Power Production on
the Nordic System " Holtinen, VTT Processes,
December 2004
Short-term Operational Impacts of Wind Generation
on the Puget Sound Energy Power System , Golden
Energy Services, Inc., March 3, 2005.
..
.
.
A
n
a
t
i
o
n
a
l
l
a
b
o
r
a
t
o
r
y
o
f
t
h
e
U
.
S.
D
e
p
a
r
t
m
e
n
t
o
f
E
n
e
r
g
y
Of
f
i
c
e
of
E
n
e
r
g
y
E
f
f
i
c
i
e
n
c
y
Re
n
e
w
a
b
l
e
E
n
e
r
g
y
.~
l
.
-
-
I
~
=
!
.
.
Na
t
i
o
n
a
l
R
e
n
e
w
a
b
l
e
E
n
e
r
g
y
L
a
b
o
r
a
t
o
r
y
In
n
o
v
a
t
i
o
n
f
o
r
O
u
r
E
n
e
r
g
y
F
u
t
u
r
e
Wi
n
d
-
Ge
n
e
r
a
t
e
d
E
l
e
c
t
r
i
c
i
t
y
:
T
e
c
h
n
0
lo
g
y
,
I
n
t
r
a
t
i
0
n
,
Tr
a
n
s
m
i
s
s
i
o
n
I
s
s
u
e
s
PN
W
E
R
An
n
u
a
l
M
e
e
t
i
n
g
An
c
h
o
r
a
g
e
,
A
l
a
s
k
a
Ju
l
y
2
4
20
0
7
Co
m
pa
r
i
s
o
n
o
f
C
o
s
t
-
Ba
s
e
d
S.
Op
e
r
a
t
i
o
n
a
l
I
m
p
a
c
t
St
u
d
i
e
s
Da
t
e
St
u
d
y
Wi
n
d
Re
g
u
l
a
-
Ca
p
a
c
i
t
y
'
ti
o
n
C
o
s
t
Pe
n
e
t
r
a
-
,
(
$
/
M
W
h
)
ti
o
n
(
%
)
Lo
a
d
Fo
l
l
o
w
i
n
g
Co
s
t
($
/
M
W
h
)
Un
i
t
Co
m
m
i
t
-
me
n
t
C
o
s
t
($
/
M
W
h
)
Ga
s
Su
p
p
l
y
Co
s
t
($
/
M
W
h
)
Ma
y
'
03
X
c
e
l
-
UW
I
G
Se
p
'
04
X
c
e
l
-
MN
D
O
C
Ju
n
e
'
06
C
A
RP
S
M
u
l
t
i
-
ye
a
r
Fe
b
'
07
GE
/
P
i
e
r
/
C
A
I
A
P
2
0
Ju
n
e
'
03
W
e
En
e
r
g
i
e
s
4
Ju
n
e
O3
We
E
n
e
r
g
i
e
s
P~
c
i
f
i
C
Q
r
p
)(
c
e
l
~
P
S
G
b
"
,
..
'~
c
e
t
~
R
S
C
(
)
0.
4
1
1.
4
4
0.
4
5
*
tr
a
c
e
tr
a
c
e
,
**
*
,
,
"
,
~p
r
i
r
'
'
'
~~
r
i
r
"
P9
'
' "
De
c
'
'
To
t
a
l
Op
e
r
a
t
i
n
g
Co
s
t
Im
p
a
c
t
($
/
M
W
h
)
0.
4
5
69
*
*
*
tr
1
...
.
(J
Q..:
:
...
.
...
.
,
p,
.
t"
'
"
t"
'
"
""
C
I
rr
,
-.
.
)
-.
.
)
..
.
.
,
..
.
.
,
::
r
:
:
..
.
.
,
t:C
PacifiCorp 2007 IRP Appendix A Base Assumptions
")iI'fjj;!I.i~:?i~;im'
2009
2010
2011
2012
2013
2014
2015
2016
2017
2018
2019
2020
2021
2022
2023
2024
2025
2026
Note: Excludes the decommissioning of Condit, Cove, Powerdale, and American Fork,
Generation Resources
Table A.12 lists operational profile information for the PacifiCorp generation resources, includ-
ing plant type, maximum megawatt capacity, ownership share, location, retirement date, andFERC Form 1 heat rates, Lake Side s heat rate has been approximated based on design expecta-
tions,
Table A.12 - Thermal and Renewable Generation Facilities
Carbon 1 Utah 100%2020 497
Carbon 2 105 Utah 100%2020 497
380 Arizona 100%2025 815
Montana 10%2029 870
Montana 10%2029 870
Colorado 19%2024 208
Craig 2 Colorado 19%2024 208
Dave Johnston 1 106 Wvoming 100%2020 047
Dave Johnston 2 106 Wyoming 100%2020 047
Dave Johnston 3 220 Wyoming 100%2020 047
Dave Johnston 4 330 Wyoming 100%2020 047
Hayden 1 Colorado 24%2024 571
PacifiCorp 2007 IRP Appendix A Base Assumptions
~ ~
Sj,
~, :.~; j
Plant e),
'" '" '" ': "."" "',, , "
Sh~U""e "
" "" "" ,
StattL
Hayden 2 Colorado 13%2024 571
Hunter 1 403 Utah 94%2031 508
Hunter 2 259 Utah 60%2031 1 0,508
Hunter 3 460 Utah 100%2031 508
Huntington 1 445 Utah 100%2025 099
Huntington 2 450 Utah 100%2025 1 0 099
Jim Bridger 1 353 Wyoming 67%2026 1 0 569
Jim Bridger 2 353 Wyoming 67%2026 569
Jim Bridger 3 353 Wyoming 67%2026 1 0 569
Jim Bridger 4 353 Wyoming 67%2026 1 0 569
Naughton 1 160 Wyoming 100%2022 1 0,426
Naughton 2 210 Wyoming 100%2022 1 0 426
Naughton 3 330 Wyoming 100%2022 1 0 426
Wyodak 1 280 Wyoming 80%2028 11,597
:Gii$~fired
, "':"" ", ," ,
Currant Creek 541 Utah 100%2040 327
Gadsby 1 Utah 100%2017 590
Gadsby 2 Utah 100%2017 590
Gadsby 3 100 Utah 100%2017 590
Gadsby 4 Utah 100%2027 556
Gadsby 5 Utah 100%2027 556
Gadsby 6 Utah 100%2027 556
Henniston 1 124 Oregon 50%2031 222
Henniston 2 124 Oregon 50%2031 222
Lake Side 3/544 Utah 100%939
West Valley 1 Utah 100%2008 694
West Valley 2 Utah 100%2008 694
West Valley 3 Utah 100%2008 694
West Valley 4 Utah 100%2008 694
West Valley 5 Utah 100%2008 694
R~'ij;~~~bleSan~()th~t't~"'" '
~~:/::
i"
' ,,' " "..:, "" "' ', ,
Blundell (Geothermal) 4/Utah 100%2033
Foote Creek (Wind)Wyoming 79%2019
Leaning Juniper (Wind)101 Oregon 100%2031
James Riyer (CHP)Washington 100%2016 200
Little Mountain (CHP)Utah 100%2009 980
1/ Plant lives are currently being reviewed for compliance with future environmental regulations,
2/ Remainder of Hetmiston plant under purchase contract by the company for a total of248 MW,
3/ Currently under construction; expected June 2007 start date.
4/ Planned Blundell bottoming-cycle upgrade of 11 MW in 2008,
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this day, October 5 , 2007, I caused a true and
correct copy of the foregoing EXERGY DEVELOPMENT GROUP OF IDAHO LLC
COMMENTS PAC-O7-07 to be served by the method indicated below, and addressed to the
following:
Ms, Jean Jewell
Commission Secretary
Idaho Public Utilities Commission
P a Box 83720
Boise 1083720-0074
( ) US, Mail, Postage Prepaid
(X) Hand Delivered
( )
Overnight Mail
( ) Facsimile
( ) Electronic Mail
Dean Brockbank
Rocky Mountain Power
201 S, Main St. Ste, 2300
Salt Lake City, Utah 84111
dean. brockbank~pacificorp,com
( ) U.S, Mail, Postage Prepaid
(X) Hand Delivered
( ) Overnight Mail
( )
Facsimile
(X) Electronic Mail
Brian Dickman
Rocky Mountain Power
201 S, Main St. Ste, 2300
Salt Lake City, Utah 84111
brian. dickman~pacificorp, com
( ) U,S. Mail, Postage Prepaid
(X) Hand Delivered
( ) Overnight Mail
( ) Facsimile
( ) Electronic Mail
Scott Woodbury
Idaho Public Utilities Commission
424 W Washington Street
Boise ID 83702
scott, woodbury~puc.idaho. gov
( ) U,S, Mail, Postage Prepaid
(X) Hand Delivered
( ) Overnight Mail
( )
Facsimile
(X) Electronic Mail
William Eddie
Advocates for the West
610 SW Alder St, Ste, 910
Portland, OR 97205
beddi e~advocateswest, org
(X) U,S, Mail, Postage Prepaid
( ) Hand Delivered
( )
Overnight Mail
( ) Facsimile
(X) Electronic Mail
EXERGY DEVELOPMENT GROUP, LLC
CERTIFICATE OF SERVICE COMMENTS PAC-07-
Glenn Ikemoto
Idaho Windfarms
672 Blair Ave
Piedmont, CA 94611
glenni~pacbell.net
(X) U,S, Mail, Postage Prepaid
( )
Hand Delivered
( )
Overnight Mail
( )
Facsimile
(X) Electronic Mail
Gary Seifert
Kurt Myers
INL Biofuels & Renewable Energy
2525 S. Fremont Ave
PO Box 1625, MS 3810
Idaho Falls, Idaho 83415-3810
Gary, seifert~inl. gov
Kurt,myers~inl,gov
(X) U,S, Mail, Postage Prepaid
( )
Hand Delivered
( )
Overnight Mail
( )
Facsimile
(X) Electronic Mail
Ken Dragoon
Renewable Northwest Project
917 SW Oak St., Ste, 303
Portland, OR 97205
ken~rnp,org
(X) u.S, Mail, Postage Prepaid
( )
Hand Delivered
( ) Overnight Mail
( ) Facsimile
(X) Electronic Mail
Dean J, Miller
PO Box 2564
Boise, Idaho 83701
i oe~mcdevitt -miller,com
(X) U,S, Mail, Postage Prepaid
( ) Hand Delivered
( ) Overnight Mail
( )
Facsimile
(X) Electronic Mail
Stephen E, Martin
Intermountain Wind LLC
425 S, Homes
PO Box 3189
Idaho Falls, Idaho 83404-3189
(X) u.S. Mail, Postage Prepaid
( ) Hand Delivered
( ) Overnight Mail
( )
Facsimile
(X) Electronic Mail
EXERGY DEVELOPMENT GROUP, LLC
CERTIFICATE OF SERVICE COMMENTS PAC-07-
R. Blair Strong
Jerry K. Boyd
Paine, Hamblen, Coffin, Brooke & Miller LLP
717 West Sprague Avenue Ste 1200
Spokane WA 99201-3505
r, blair ,strong~painehamblen,com
Michael G. Andrea
Staff Attorney
1411 E Mission Ave
PO Box 3727 MSC-
Spokane W A 99201
Mi chae 1, andrea~a vi stac orp, com
Peter Richardson
ISB # 3195
(X) U,S, Mail, Postage Prepaid
( )
Hand Delivered
( )
Overnight Mail
( )
Facsimile
(X) Electronic Mail
(X) D.S, Mail, Postage Prepaid
( ) Hand Delivered
( ) Overnight Mail
( )
Facsimile
(X) Electronic Mail
EXERGY DEVELOPMENT GROUP, LLC
CERTIFICATE OF SERVICE COMMENTS PAC-07-