20210728IPC to Staff 1-14.pdf

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An loAcoRP company
July 28,2021
VIA ELECTRONIC FILING
Jan Noriyuki, Secretary
ldaho Public Utilities Commission
11331 W. Chinden Blvd., BIdg 8,
Suite 201-A(83714)
PO Box 83720
Boise, ldaho 83720-0074
Re: Case No. IPC-E-21-13
ln the Matter of ldaho Power Company's Application for Approval of Its Load
Curtailment and lnterruption Plan
Dear Ms. Noriyuki:
Enclosed for electronic filing, pursuant to Order No. 35058, please find ldaho Power
Company's Response to the First Production Request of the Commission Staff.
Please handle the confidential information in accordance with the Protective
Agreement executed in this mafter.
If you have any questions about the attached documents, please do not hesitate to
contact me.
Very truly yours,
. rlr -11',.'::i! |r "L'..:-i ! L-r:
LISA D. NORDSTROM
Lead Counsel
I [e-mail]
LDN:sg
Enclosures
X*!.("1-t,.*,
Lisa D. Nordstrom
LISA D. NORDSTROM (lSB No. 5733)
ldaho Power Company
1221 West ldaho Street (83702)
P.O. Box 70
Boise, ldaho 83707
Telephone: [phone]
Facsimile: [phone]
I n ord strom@ ida hopowe r. com
Attorney for ldaho Power Company
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF IDAHO POWER
COMPANY'S APPLICATION FOR
APPROVAL OF ITS LOAD
CURTAI LMENT AND INTERRU PTION
PLAN
CASE NO. IPC-E-21-13
IDAHO POWER COMPANY'S
RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE
COMMISSION STAFF
COMES NOW, ldaho Power Company ("ldaho Powe/' or "Company"), and in
response to the First Production Request of the Commission Staff dated July 7, 2021,
submits the following information:
IDAHO POWER COMPANY'S RESPONSETO THE FIRST PRODUCTION REQUEST OF
COMMISSION STAFF.l
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REQUEST NO. 1: Company Wtness Anderson's direct testimony states that the
Company's current reliability coordinator is operated by the California lndependent
System Operator ("CA!SO'). Anderson Dl at 4.
a. Please provide current copies of CAISO curtailment procedures and
requirements the Company is expected to comply with.
b. Please explain how the Load Curtailment and Interruption Plan ("LCIP") and
modified Rule J align with and support CAISO curtailment procedures and
requirements.
c. Please explain if CAISO has requested the Company to curtail since becoming
the Company's reliability coordinator in 2018. lf so, please provide dates, size,
duration, and reason for each curtailment.
RESPONSE TO REQUEST NO. 1:
a. Provided as Attachment No. 1 to this Response is a copy of the RC West's
System Emergencies Procedure RC0410, V3.2, as downloaded from RC
West's portal on July 9, 2021, at the following address:
http ://www. ca iso. co m/Docu me nts/RC 04 1 0. pdf .
b. According to RC West's RC0410 Procedure and NERC EOP-011-1 R2, each
Balancing Authority shall develop, maintain, and implement an RC-reviewed
operating plan to mitigate capacity and energy emergencies within its balancing
authority area. ldaho Power has filed with the RC West its Load Management
Procedures ("LMP"). The Load Curtailment and lnterruption Plan ("LClP")
incorporated into the proposed Rule J outlines requirements at a higher level
than what is contained in the detailed LMP. Therefore, the LCIP aligns and
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF
COMMISSION STAFF - 2
supports the required procedures for capacity and energy emergencies
outlined in the RC West RC0410. The current LMP is provided as Confidential
Attachment No. 2 and the RC review acknowledgment is provided as
Attachment No. 3 to this Response.
c. Since becoming a customer of RC West, ldaho Power has not received a
request from RC West to curtail.
The response to this Request is sponsored by Kathy Anderson, Senior Manager
Real Time Operations and Markets, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF
COMMISSION STAFF - 3
REQUEST NO. 2: Please describe how the Company provides notification of
curtailment or interruption to state regulatory and reliability authorities. Please provide
supporting documentation and examples.
RESPONSE TO REQUEST NO. 2: The primary state regulatory authorities
notified would be the ldaho Public Utilities Commission and/or the Public Utility
Commission of Oregon. Under the Company's Emergency Response Communication
Plan ("ERCP'), provided as a Confidential attachment to this request, the designated
Communication Coordinator notifies several critical internal groups including the Legal
and Regulatory Affairs departments. lf circumstances giving rise to the interruption or
curtailment are likely to be of significant public impact or attention, Regulatory Affairs will
contact the ldaho Public Utilities Commission ("lPUC") and/or Public Utility Commission
of Oregon ('OPUC') to notify them of the event and provide updates as the situation
warrants.
Further, the Company's Emergency Management Team ("EMT') will contact the
ldaho and Oregon Offices of Emergency Management depending on the type and
severity of the event. The role of the EMTwilldepend on if the event impacts the continuity
of critical business functions and/or the severity of the event.
These types of communications are envisioned to occur via direct phone cal!, so
the Company does not have record of specific communications to state regulatory and
reliability authorities.
The response to this Request is sponsored by Connie Aschenbrenner, Rate
Design Senior Manager, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF
COMMISSION STAFF - 4
REQUEST NO. 3: Please explain how customers were notified of the proposed
LCIP and Rule J modifications and provide supporting documentation.
RESPONSE TO REQUEST NO. 3: The Commission's Notice of Application
issued July 13,2021, in Order No. 35101 provided broad notice to customers and
stakeholders of the Company's Application in this matter. Idaho Power has not provided
separate notification to customers regarding the proposed Load Curtailment and
lnterruption Plan and Rule J modifications.
The response to this Request is sponsored by Lisa Nordstrom, Lead Counsel,
ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF
COMMISSION STAFF - 5
REQUEST NO. 4: PIease describe how the Company provides notification of
curtailment or interruption to customers and the public. Please provide supporting
documentation and examples.
RESPONSE TO REQUEST NO.4: As described in more detail in the direct filed
testimony of Company witness Kathleen Anderson, Customers are able to get outage
information through customer service, online at idahopower.com, by subscribing to text
alerts and through public communication via media and social media outreach. Other
channels of communication targeted at individual customers could include call outs, texts
and emails.
The communication process begins with the interna! notifications outlined in the
company's Emergency Response Communication Plan (ERCP). The designated
Communication Coordinator notifies several critical groups including Corporate
Communications, Customer Service, lT, Legal and ldaho Power's Emergency
Management Team. This also starts the chain of communication with customers. The
ERCP is provided as a confidential attachment to Staff Request No. 2.
Efforts specifically within Corporate Communications are provided in the attached
Confidential Attachment 1 to this request, which provides an outline of the tasks to be
performed immediately after a load shed event begins. The document also provides
example communications recently used for a "Lighten the Load" campaign. Because the
company has not had to use curtailment communications, it does not have any examples
of curtailment communications that have already been used. The Company does have
draft materials ready to be tailored to a load shed event if needed and has provided an
illustrative social media post as Attachment 2 to this request.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCT]ON REQUEST OF
COMMISSION STAFF -6
The response to this Request is sponsored by Erica Shiflet, Extemal
Communications Leader, ldaho Power Company.
IDAHO POVI'ER COMPANYS RESPONSETO THE FIRST PRODUCTION REQUEST OF
COMMISSION STAFF. T
REQUEST NO. 5: Please explain how Iegacy stakeholders and contractual
customers were notified of the proposed LCIP and Rule J modifications. Please provide
supporting documentation.
RESPONSE TO REQUEST NO. 5: The Commission's Notice of
Application issued July 13, 2021, in Order No. 35101 provided broad public notice,
including to contract customers and legacy stakeholders, of the Company's Application
in this matter. Idaho Power has not provided separate notification to contract customers
or legacy stakeholders regarding the proposed LCIP and Rule J modifications.
The response to this Request is sponsored by Lisa Nordstrom, Lead Counsel,
ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF
COMMISSION STAFF - 8
REQUEST NO. 6: Please explain how Demand Response participants were
notified of the proposed LCIP and Rule J modifications. Please provide supporting
documentation.
RESPONSE TO REQUEST NO. 6: The Commission's Notice of
Application issued July 13, 2021, in Order No. 35101 provided broad notice to demand
response participants of the Company's Application in this matter. ldaho Power has not
provided separate notification to demand response participants regarding the proposed
Load Curtailment and lnterruption Plan and Rule J modifications.
The response to this Request is sponsored by Lisa Nordstrom, Lead Counsel,
ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF
COMMISSION STAFF - 9
REQUEST NO. 7: Company \Mtness Anderson's direct testimony states
"Over time, changes in technology, modifications to industry practices, and changes
in generation capacity have served to make the existing Modified Regional Plan
obsolete." Anderson Dl at 3.
a. lf the Modified Regiona! Plan is obsolete at the regional level, please explain
how regional partners and stakeholders are addressing curtailment planning
and notification.
b. PIease provide copies of Company, regional partner, and stakeholder
correspondence regarding current regional curtailment planning activities and
status of the Modified Regional Plan.
c. Please provide current copies of any documents that place the Modified
Regional Plan document in an "obsolete" status.
RESPONSE TO REQUEST NO. 7:
a. The Energy Policy Act of 2005 established the Electric Reliability Organization
("ERO'), which is an independent entity charged with developing and enforcing
mandatory standards for the reliable operation and planning of the bulk power
system through North America. The North American Electric Reliability
Corporation ("NERC") was designated as the ERO by the Federal Energy
Regulatory Commission in July 2006. Mandatory standards began to replace
the previously negotiated agreements among parties related to reliability of
their interconnected systems. Today, effective NERC Emergency
Preparedness and Operations ("EOP') standards address emergency
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF
COMMISSION STAFF - 1O
operations and the requirement to coordinate emergency operating plans
through the Reliability Coordinator ("RC").
ln addition to the emergency operating plans required to be coordinated
through the RC, ldaho Power and other Northwest Power Pool ("N\A/PP";
members have included the option of calling on the reserve sharing program
when a member is in a declared NERC-defined Energy Emergence Alert
("EEA')-1 or higher to potentially avoid a load shed situation. The NWPP
program documentation outlines howthe program can be used forthat purpose
and is available at httos : //www. nwnn. o rolres rces/nwoo-rese rve-sha ri nq -
p roq ram-documentation.
b. There is no current regionalcurtailment planning beyond those provided under
the Company's Response to Staff Request No. 1 regarding the Reliability
Coordinator Emergency Operations plans. Curtailment planning and
coordination changed from a regionalfocus to a Balancing Authority/RC focus
when the NERC Standards became mandatory. ldaho Power does not
possess documentation to when the Modified Regional Plan was officially
terminated or superseded. ldaho Power inquired of the NWPP, who was
identified as the Utility Coordinator in the plan, for any historical information that
it can provide. The N\A/PP indicated that current employees are not aware of
the program or its history, however, reached out to retired employees to see
what could be recalled. Those employees indicated the program was
eliminated as a result of FERC orders 888 and 889 regarding Open Access
Transmission.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF
COMMISSION STAFF - 11
c" See the response to b. above.
The response to this Request is sponsored by Kathy Anderson, Real Time
Operations and Markets Senior Manager, ldaho Power Company.
IDAHO POYVER COMPANYS RESPONSE TO THE FIRST PRODUCTION REQUEST OF
COMMISSION STAFF - 12
REQUEST NO. 8: Regarding page 9 of Kathleen Anderson's direct testimony,
how are "facilities essentialto the public welfare" determined, tracked, and notified?
RESPONSE TO REQUEST NO. 8: ldaho Power's service operations are
segmented into five regions. The regional leadership overseeing each service region is
responsible for identifying distribution feeders used in ldaho Power's initialautomatic load
shed program. The review by the regiona! leadership looks to ensure that the initial load
shed feeders programed into the emergency management system do not include
hospitals, care facilities, fire or police emergency response facilities. The feeder list is
reviewed for summer and winter rotations. The regional leadership are aware of the
location of the emergency response facilities, such as hospitals, care facilities, and other
facilities and avoid recommending those feeders for initial Ioad shed.
The response to this Request is sponsored by Kathy Anderson, Real Time
Operations and Markets Senior Manager, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF
COMMISSION STAFF - 13
REQUEST NO. 9: Table 1 on page 2 of the LCIP states "as required by NERC
Standards." What are the NERC standards that are referenced in the LCIP?
RESPONSE TO REQUEST NO. 9: NERC Standard EOP-011-1 is the current
emergency operations standard in effect. This standard is available at the NERC website
at https://www.nerc.com/palStand/Reliabilitv%20Standards/EOP-01 1-1.pdf.
The response to this Request is sponsored by Kathy Anderson, Real Time
Operations and Markets Senior Manager, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF
COMMISSION STAFF.14
REQUEST NO. 10: Page 4 of the Application states that the LCIP applies to
emergencies declared by state entities, and when directed by the North American Electric
Reliability Corporation ('NERC') or the Western Electricity Coordinating Council
("WECC"), and by the Company at its own discretion.
a. PIease describe the process for resolution if one entity's declaration conflicts
with the decisions of another entity.
b. Please describe the scope and provide examples for the types of emergencies
that can be declared by the various entities mentioned above
RESPONSE TO REQUEST NO. 10:
a. Decisions regarding emergencies are communicated and coordinated through
the RC to ensure the stability of the bulk electric system. The purpose of NERC
standard EOP-011-1 is to address the effects of operating emergencies by
ensuring each transmission operator and balancing authority has developed
operating plan(s) to mitigate operating emergencies, and that those plans are
coordinated within a RC Area. The RC will work with each impacted
transmission operator and balancing authority to ensure reliability is met. The
RC can ultimately determine the best course of action for the reliability of the
interconnection should conflicting decisions occur. When emergency
operations arise within a Balancing Authority in real time, there is generally a
high level of coordination between the RC and any impacted parties to discuss
what is going on and what actions can be taken.
b. NERC and the Western Electricity Coordinating Council (WECC) do not direct
individual entities in real time to declare emergencies. The NERC standard
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF
COMMISSION STAFF - 15
EOP-011-1 directs entities to work through RCs to declare those. As a result,
it is difficult to see a scope or example that comes from NERCM/ECC rather
than the RC.
As for state entities, such instances could include localized flooding, fire
danger, earthquakes, or tornados. lf a state entity feels the need to curtail
power to an area for public safety, the request can be made of ldaho Power
and curtailment could occur.
The Company could call for emergency curtailments for transmission
system emergencies outlined in the RC West's Procedure RC0410 section 3.2
(provided in response 1) or in the interest of public safety as noted for state
entities.
The response to this Request is sponsored by Kathy Anderson, Real Time
Operations and Markets Senior Manager, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF
COMMISSION STAFF - 16
REQUEST NO. 1{: Please describe how the Company notifies customers and the
public of return to service. Please provide supporting documentation and examples.
RESPONSE TO REQUEST NO. 11: The Company uses several methods to keep
customers and the public informed regarding curtailments and interruptions. Please see
the Emergency Response Communication Plan provided as a confidential attachment to
the Company's response to Staff Request No. 2 and the attachment to the Company's
response to Staff Request No. 4.
The response to this Request is sponsored by Erica Shiflet, Externa!
Communications Leader, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF
COMMISSION STAFF - 17
REQUEST NO. 12: Page 5 of the Application states the Modified Regional Plan
has addressed only long-term regional energy shortages, while the Rule J procedures
cover short-term emergencies. ln contrast, lhe 2021 LCIP contains both short- and long-
term operational activities the Company can initiate during emergencies to minimize
adverse impacts to customers and restore system stability. Please answer the following
questions:
a. Which long-term components of the LCIP are common with the Modified
Regiona! Plan?
b. Which short-term components of the LCIP are covered by the Rule J
Procedures?
RESPONSE TO REQUEST NO. 12: Idaho Power does not consider curtailments
and interruptions defined as long or short-term; they simply result from a specific situation
or circumstance and can vary in duration. Prior to NERC standards, coordination
agreements among states and neighboring utilities was more of a voluntary necessity
than a mandatory requirement. Today the Company and other utilities still do that
coordinating out of voluntary necessity, but it comes in the form of Reserve Sharing
Programs and a potential Resource Adequacy program such as the one the Northwest
Power Pool is looking to establish and not in the form of bi-lateral agreements of
curtailment procedures. Today, load curtailment procedures are created by each
Balancing Authority and Transmission Operator and coordinated through the RC. These
are enacted regardless of whether the energy shortage is shorter-term or longer-term. lf
curtailments are necessary, they follow the procedures coordinated with the RG.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF
COMMISSION STAFF - 18
a. The Modified Regional Curtailment PIan identified an entire process in which
regional curtailments could be issued by the state in a coordinated manner due
to more regionalenergy shortage issues such as low hydro. LCIP simplifies this
process by stating ldaho Power will comply with all state and federal mandates
to curtail the electric energy used to prevent an electrical system collapse. lt
doesn't set out a plan specific to the state or region alone but allows for ldaho
Power to continue to follow the processes outlined in its emergency operation
plan coordinated with the RC. This allows better coordinated reliability for the
interconnection. ln addition, it allows for a single plan to follow regardless of the
duration of the energy shortage.
b. The entire LCIP is included in the Rule J Procedures. This is to align al!
curtailment plans (State and NERC required) to focus on the actua! curtailment
and interruption in the same manner regardless of the circumstance creating
the need for the plan's activation.
The response to this Request is sponsored by Kathy Anderson, Real Time
Operations and Markets Senior Manager, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF
COMMISS]ON STAFF - 19
REQUEST NO. l3: Page 5 of the Application states that the 2021 LCIP addresses
the Company's operational approach to lnitiation of Load Curtailment; Automatic, Remote
and ManualActions; Curtailment Stages; lnterruptible Loads; BIock Rotation; Emergency
Load Shed Groups; and Return to Service. PIease answer the following questions:
a. ls each item listed above implemented differently under a short-term
emergency versus a long-term emergency? lf so, please describe the
difference.
b. Does the Modified Regional Plan address each item? lf so, how does the
Modified Regional Plan address each item? Are there any differences between
the Modified Regional Plan and the LCIP for each item?
c. Do the Rule J Procedures address each item listed above? If so, how do the
Rule J procedures address each item? ls there any difference between the
Rule J procedures and the LCIP on each item?
RESPONSE TO REQUEST NO. 13:
a. ldaho Power implements each action item the same regardless of the duration
of the emergency. The need for curtailments and interruptions is based on
specific situations; how long those situations or conditions continue drives the
duration.
b. The Modified Regional Curtailment PIan was a plan that was for State-
lmplemented curtailment needs, not needs specific only to an individua! utility's
area. lt identified curtailment stages that could be used that would apply to all
regional loads. The curtailment stages identifled in the Modified Regional Plan
are specific to percent of load curtailments while the LCIP curtailment stages
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF
COMMISSION STAFF - 20
align with the Energy Emergency Stages outlined in NERC EOP-011-1. The
curtailments identified in step 3 or 4 of the LCIP as emergency load shed are
not based on a percentage of load needed but instead on the actual load
megawatt value needed to preserve the reliability of the system. The LCIP is
only for ldaho Power and not a regional basis.
The Modified Regional Curtailment Plan also had a return to service
section focused on actions that are based on the State declaring an end for the
curtailment and included three specific steps: 1) lnform the public the
curtailment is no longer needed, 2) take care of alladministrative matters under
the plan such as reporting and incentive or penalty assessments, and 3) State
rescinds any State orders for mandatory load curtailment. The LCIP doesn't
address the three steps listed in the Modified Regional Curtailment Plan but
instead focuses on when ldaho Power is able to return to service rather than
how ldaho Power will do it.
c. The Rule J incorporates the entire LCIP into it. This was intentional to ensure
that the two plans were the same and administered the same.
The response to this Request is sponsored by Kathy Anderson, Real Time
Operations and Markets Senior Manager, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF
COMMISSION STAFF - 21
REQUEST NO. 14: If the LCIP is approved, is the Company still going to
implement the Modified Regional Plan? Does the LCIP replace the Modified Regional
PIan? Please explain.
RESPONSE TO REQUEST NO. 14: As noted in the Company's Application and
responses to Staffs data requests, the Modified Regional Plan is obsolete. The LCIP
replaces the Modified Plan.
The response to this Request is sponsored by Kathy Anderson, Real Time
Operations and Markets Senior Manager, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF
COMMISSION STAFF - 22
DATED at Boise, ldaho, this 28th day of July 2021.
X*fr-ffa"+,,"*,
LISA D. NORDSTROM
Attorney for ldaho Power Company
IDAHO POVVER COMPANYS RESPONSE TOTHE FIRST PRODUCTION REQUEST OF
COMMISSION STAFF - 23
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 28th day of July 2021, I served a true and correct
copy of IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE COMMISSON STAFF upon the following named parties by the
method indicated below, and addressed to the following:
Commission Staff
Dayn Hardie
Deputy Attorney General
ldaho Public Utilitles Commission
11331 W. Chinden Blvd., Bldg No. 8,
Suite 201-A(83714)
PO Box 83720
Boise, lD 83720-0074
ldaho lrrigation Pumpers Association, lnc.
Eric L. Olsen
ECHO HAWK & OLSEN, PLLC
505 Pershing Ave., Ste. 100
Pocatello, ldaho 83205
Hand Delivered
_U.S. Mail
Overnight Mai!
-FAX
X Email [e-mail]
FTP Site
Hand Delivered
_U.S. Mail
_Overnight Mail
FA)(XEm ail [e-mail]
FTP Site
(}r"t.
Stacy Gust, Regulatory Administrative
Assistant
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF
COMMISSION STAFF - 24
BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
GASE NO. IPC-E-21-13
IDAHO POWER COMPANY
REQUEST NO. 1
ATTACHMENT NO. 1
$ Colifornio ISO RC West Reliability
Goordinator
Procedure
Procedure No.RC0410
Version No.3.2
Effective Date 612112021
System Emergencies Distribution Restriction:
None
Table of Gontents
Purpose
1. Responsibilities.....
2. Scope/Applicability
3. Procedure Detail
3.1. Capacity and Energy Emergencies............
3.1.1. EEA Watch
3.1.2. EEA 1 -AllAvailable Generation in Use..........
3.1.3. EEA2 - Load Management Procedures in Effect........
3.1.4. EEA 3 - Firm Load Shedding lmminent or in Progress.
3.1.5. EEA 0 - Termination ..
3.1.6. EEATemplates.........
3.2. Transmission System Emergencies................
3.3. Extreme Weather Emergencies.............
3.4. Operating lnstructions
3.5. Load Shedding lnstructions
3.5.1. Situations that May Require Load Shedding.............
3.5.2. When Load Shedding lnstruction May Not Be Viable
3.6. Event Reporting..
3.7. BA and TOP EOP-01 1 Plan Submissions and Review
4. Supporting lnformation
Operationally Affected Parties
References
Definitions.
Version History
5. Periodic Review Procedure.
Review Criteria & lncorporation of Changes
Frequency
2
2
2
2
2
...3
...3
,,,4
... 5
...7
...7
...8
...9
.11
.11
.12
.12
.13
.13
.14
.14
.14
.14
.16
.17
.17
.17
.17
This document is controlled when viewed electronically.
When downloaded or printed, this document becomes UNCONTROLLED.
1
Appendix
2. Scope/Appl icabi I ity
$ Colif"rnio ISO . RC West Reliability
Goordinator
Procedure
Procedure No.RC0410
Version No.3.2
Effective Date 612112021
System Emergencies Distribution Restriction
None
Purpose
Provide guidance on mitigating transmission system operating Emergencies; Capacity and Energy
Emergencies; and extreme weather and environmental Emergencies. Provide the RC's philosophy on
load shedding.
1. Responsibilities
. ReliabilityCoordinatorOperator
. Operations Compliance Support
Reliability Coordination during Bulk Electric Sysfem (BES) Emergencies or during conditions or
events that could result in Adverse Reliability lmpact on the BES.
o As defined in the NERC Glossary, a BES Emergency is any abnormal system condition that
requires automatic or immediate manual action to prevent or limit the failure of transmission
facilities or generation supply that could adversely affect the reliability of the BES.
o ln addition, the NERC Glossary defines Adverse Reliability lmpact as the impact of an event
that results in frequency-related instability, unplanned tripping of load or generation, or
uncontrolled separation or cascading outages that affects a widespread area of the
!nterconnection.
3. Procedure Detail
3.1. Capacity and Energy Emergencies
Each Balancing Authority (BA) shall develop, maintain, and implement an RC-reviewed Operating
Plan to mitigate Capacity and Energy Emergencies within its Balancing Authority Area.1 During a BA
Capacity or Energy Emergency, the RC operator will declare an Energy Emergency Alert (EEA) for
the affected entity. This may be at the request of the BA, or when deemed necessary in the judgment
of the RC operator.
There are three levels of EEAs and an additional termination level.2 lt is not necessary to progress
through the levels sequentially, and the RC operator should use good judgment in declaring the level
best defined by the criteria. Public appeals for conservation or demand response programs under
contractual agreements during normal operations do not qualify as EEA triggering events.
l EOP-011-1 R2
2 Attachment 1-EOP-011-1 B.
This document is controlled when viewed electronically.
When downloaded or printed, this document becomes UNCONTROLLED.
2
a
fr) Collf"rnio ISO RC West Reliability
Coordinator
Procedure
Procedure No.RC0410
Version No.3.2
Effective Date 612112021
System Emergencies Distribution Restriction
None
lf a BA forecasts a potential energy or capacity deficiency one or more days prior to the operating
day, the BA may request the RC operator to declare an "EEAWatch" before the operating day. A BA
may also choose to request an EEA Watch during the operating day if the BA is concerned about
potential energy or capacity issues in advance of the forecasted shortage. E.g. for a forecasted
shortage at 1300 a BA may request issuing an EEA Watch declaration during the moming hours,
normally this would be three or more hours in advance. This proactive notification may be helpful to
assist the BA procure additional energy or capacity.
Following the activation of Contingency Reserves, a BA or Reserve Sharing Group (RSG) must
recover Contingency Reserves within 60 minutes following an event requiring activation. lf there is
an additional event that takes place during this recovery period, the 60-minute recovery period resets.
The RC operator should not declare an EEA for a BA during this recovery period unless requested
by the BA, or if the RC operator, after consultation with the BA, has reason to believe that the BA will
not be able to recover their Contingency Reserves within the recovery period.
3.1.1. EEAWatch
A BA may request the RC operator to declare an "EEA Watch" one or more days prior to the
operating day, or during the operating day, if the BA forecasts being in an EEA level.
3.1.2. EEA 1 - All Available Generation in Use
A BA is considered to be in EEA 1 when all available generation resources are in use and/or:
r The BA is experiencing conditions where all available generation resources are committed to
meet firm Load, firm transactions, and reserve commitments, and is concerned about
sustaining its required Contingency Reserves.
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Reliability Coordinator Actions
. Discuss with the BA forecasting a potential energy or capacity deficiency, and
. Determine whether an EEA Watch would be desired and the applicable day (date)
and/or time period.
. Upon request by the BA, declare an EEA Watch via a WECC-wide GMS message,
notifying all BAs, TOPs and Western RCs (See Section 3.1.6 for templates).
o Notify market participants in the RC Area via GMS.
o Cancel EEA Watch via GMS, if conditions change, and the BA no longer forecasts being
in an EEA.
@ Colif"rnio lSO RC West Reliability
Coordinator
Procedure
Procedure No.RC0410
Version No.3.2
Effective Date 612112021
System Emergencies Distri bution Restriction
None
a Non-firm wholesale energy sales (other than those that are recallable to meet reserve
requirements) have been curtailed.3
3.1.3. EEA2 - Load Management Procedures in Effect
A BA is considered to be in EEA2 when load management procedures are in effect and/or:
. The Balancing Authority is no longer able to provide its expected energy requirements and is
an energy-deficient Balancing Authority.
o An energy-deficient Balancing Authority has implemented its Operating Plan(s) to mitigate
Emergencies.
3 Attachment 1-EOP-011-1 Section B-1l EOP-011-1 R5.
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Rel iabil ity Coordinator Actions
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a
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Discuss with BA not meeting its Contingency Reserve requirements and evaluate
mitigation options based on guidelines provided in RC West Operating Procedure
RC0210 [\4onitorinq Frequencv and Balancinq Authority Performance.
o Determine if the BA is part of an RSG, if Contingency Reserves are deliverable
to the BA and if the BA will require an EEA to get assistance from the RSG
(Refer fo Secfion 3.4.2 of RC0210).
Evaluate whether the criteria for EEA 1 is met, if the BA is not part of an RSG or RSG
reserves is not adequate or deliverable.
o Determine status of generation in the BA and if all generation within the BA is
committed to meet firm load, firm transactions and reserve commitments.
o Determine whether the BA is concerned about sustaining its required
Contingency Reserves.
o Determine whether the BA has curtailed wholesale energy sales (other than
those that are recallable to meet reserve requirements).
Upon discussion with the BA, declare an EEA 7 for the BA if the criteria for EEA 1 is
met, or if requested by the BA.
lssue an alert to all impacted entities without delav, but not longer than within 30
minutesfrom time of the declaration:a
o Notify all BAs, TOPs, and Western RCs via GMS WECC-Wide message.
o Notify market participants in the RC Area via GMS.
o Send RCIS message.
Notification should include the name of the BA, the EEA level, and if necessary, contact
information that other BAs can use to provide emergency assistance.
Update RCIS and GMS with any changes in information.
a
o
I Colifornio ISO RC West Reliability
Coordinator
Procedure
Procedure No.RC0410
Version No.3.2
Effective Date 6t21t2021
System Emergencies Distribution Restriction :
None
o An energy-deficient BA is stillable to maintain minimum Contingency Reserve requirements.s
Once an EEA 2 has been declared, the BA should provide periodic updates to the RC operator
at a minimum of every hour until the EEA2 has been terminated.6
3.1.4. EEA 3 - Firm Load Shedding lmminent or in Progress
A BA is considered to be in an EEA 3 condition when firm load interruption is imminent or in
progress and the energy-deficient BA is unable to meet minimum Contingency Reserve
requirements.
5 Aftachment 1-EOP-011-1 Section B-2
6 Attachment 1-EOP-011-1 Section B-2.2 (applicable to BA)
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5
Rel iabil ity Goordi nator Actions
o Discuss with BA not meeting its Contingency Reserve requirements and evaluate mitigation
options based on guidelines provided in RC West Operating Procedure RC0210 Monitorino
Frequencv and Balancino Authoritv Performance.
o Determine if the BA is part of an RSG, if Contingency Reserves are deliverable to the
BA and if the BA will require an EEA to get assistance from the RSG (Refer to Section
3.4.2 of RC0210).
e Evaluate whether the criteria for EEA 2 is met, if the BA is not part of an RSG or RSG
reserves is not adequate or deliverable.
o Determine whether options available to the BA under the criteria for EEA t have been
exhausted.
o Determine whether the BA is implementing demand response or other load
management procedures.
o Upon discussion with the BA, declare an EEA 2 for the BA if the criteria for EEA 2 is met or
if requested by the BA.
o lssue an alert to all impacted entities without delav, but not longer than within 30 minutes
from time of the declaration:
o Notify all BAs, TOPs, and Western RCs via GMS WECC-Wide message.
o Notify market participants in the RC Area via GMS.
o Send RCIS message.
Notification should include the time of declaration, the BA name, the EEA level, and contact
information that other BAs can use to provide emergency assistance.
o Update RCIS and GMS with any changes in information.
o Review Transmission oufages and work with TOPs for viability of returning transmission
elements that may relieve loading on SOLs or IROLs for the possibility of energy delivery.
S Colifornio ISO RC West Reliability
Coordinator
Procedure
Procedure No.RC0410
Version No.3.2
Effective Date 612112021
System Emergencies Distribution Restriction :
None
Before requesting an EEA 3, the energy-deficient BA must make use of all available resources;
this includes, but is not limited to:
o Ensuring all available generation units are online and all generation capable of being on line
within the time frame of the Emergency is on line.
o Activating Demand-Side Management within provisions of any applicable agreements.T
The energy-deficient BA is responsible for updating the RC operator at a minimum of every hour
until the EEA 3 is terminated.s
7 Attachment 1-EOP-011-1 Section B-2.5I Aftachment 1-EOP-011-1 Section B-3.2 (applicable to BA)
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Reliability Goordinator Actions
o Discuss with BA not meeting its Contingency Reserve requirements and evaluate mitigation
options based on guidelines provided in RC West Operating Procedure RC0210 Monitorinq
Frequencv and Balancinq Authoritv Performance.
o Determine if the BA is part of an RSG, if Contingency Reserves are deliverable to the
BA and if the BA will require an EEA to get assistance from the RSG (Refer to Section
3.4.2 of RC0210)
o Evaluate whether the criteria for EEA 3 is met, if the BA is not part of an RSG or RSG
reserves is not adequate or deliverable.
o Determine whether options available to the BA under the criteria for EEA 1 and EEA2
have been exhausted.
o Verify all available generation in the BA are committed to meet firm load, firm
transactions and meet reserves.
o Verify all available demand-side management have been activated.
. Upon discussion with the BA, declare an EEA 3 for the BA if the criteria for EEA 3 is met or
if requested by the BA.
o Continue acfions initiated during the EEA 2.
o lssue an alert to all impacted entities without delav, but not longer than 30 minutes from
time of the declaration:
o Notify all BAs, TOPs, and Western RCs via GMS WECC-Wide message.
o Notify market participants in the RC Area via GMS.
o Send RCIS message.
Notification should include the name of the BA, the EEA level, and contact information that
other BAs can use to provide emergency assistance.
o Update RCIS and GMS with any changes in information.
{} Colifornio ISO RC West Reliability
Coordinator
Procedure
Procedure No.RC0410
Version No.3.2
Effective Date 612112021
System Emergencies Distri bution Restriction
None
Reliability Coordinator Actions
o Evaluate the risks of revising SOLs and /ROLs for the possibility of delivery of energy to the
energy-deficient BA.
IVofe.' This must be coordinated with other RCs with agreement from the responsible TOP.
o Request the BA to provide updates at a minimum every hour until the EEA 3 is terminated.
o Notify internal parties to ensure the appropriate report is submitted per RC West Operating
Procedure RC0420 Event Reportinq.
3.1.5. EEA0 - Termination
When the energy-deficient BA is able to meet its Load and Operating Reserve requirements, it
shall request the Reliability Coordinator Operator to terminate the EEA.
3.1.6. EEA Templates
When declaring an EEA, the RC operator may use the following templates. lnclude any additional
information as necessary.
. Subject EEA 11,2, or 3l Declaration
o Effective XXXX PPT, RC West has declared an EEA-[1 ,2, ot 3] for [entity and/or entity
area (if applicable)1. Please contact them at (XXX) XXX-XXXX if you can provide them
with emergency assistance.
. Subject: EEA 0 Declaration
o Effective XXXX PPT, RC West has declared an EEA-O for [entity and/or entity area (if
applicable)1.
o Subject: EEA Watch Declarationo Effective XXXX PPT, [Entity] is forecasting being in an EEA from [)fi] PPT to IYYJ PPT
on [Date]. Please contact the entity at ()0{X) XXX-XXXX if you can provide assistance.
. Subject EEA Watch Cancellationo Effective XXXX PPT, EEA Watch for [Entity] has been cancelled.
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Reliability Coordinator Actions
. Confirm with BA that it meets the criteria for EEA Termination.
o Notify all applicable entities of the termination.
o Notify all BAs, TOPs, and Western RCs via GMS WECC-Wide message.
o Notify market participants in the RC Area via GMS.
o Send RCIS message.
$ Colifornio ISO RC West Reliability
Coordinator
Procedure
Procedure No.RC0410
Version No.3.2
Effective Date 612112021
System Emergencies Distri bution Restriction
None
3.2. Transmission System Emergencies
TOPs are expected to have Operating Plans reviewed by the RC entity to mitigate transmission
system Emergencies in their area, and to notify the RC operator in real-time when the TOP is
experiencing an Emergency.e A Transmission system Emergency may include, but is not limited to:
o An actual or potential IROL exceedance,
. An actual or potential SOL exceedance with potentialAdverse Reliability lmpact,
o Unacceptable voltage levels with potentialAdverse Reliability lmpact,
o Loss of reactive reserves with potential Adverse Reliability lmpact,
o Loss or potential loss of transmission elements due to fires, earthquakes, storms, physical
attacks, vandalism or other reasons, with potential Adverse Reliability lmpact,
. A single or credible multiple Contingency will result in instability, uncontrolled separation, or
cascading outages that adversely impact the reliability of the BES,
o System separation, islanding or Open Loop,
o Extraordinary Contingency, and
. Any other transmission event that result in Adverse Reliability lmpact.
When the RC operator receives a notification from a TOP of a BES Emergency on the transmission
system, or if RC west analysis indicate that an Emergency condition exists,
Reliability Coordinator Actions
o Confirm the Emergency condition in collaboration with the affected TOPs.
o Actively evaluate system conditions and determine mitigation options in coordination with
TOPs contributing to and/or affected by the condition.
TOP Operating Plans include (but not limited to) mitigation optionslo such as:
o Cancelling or recalling transmission and generation outages,
o Reconfiguring transmission system,
o Re-dispatching generation, and
o Operator-controlled manual load shedding that minimizes overlap with automatic load
shedding, and is capable of being implemented in a timeframe for mitigating the
Emergency.
Refer to RC West Operating Procedure RC0460 Reliability Coordinator Area Restoration
Plan if electrical islanding has occuned.
Determine if there are any SOL or IROL exceedances
a
a
e EOP-011-'1 R1 (applicable to TOP)
r0 EOP-0'11-1 R1.2 (applicable to TOP)
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8
fr) Colifornio ISO RC West Reliability
Coordinator
Procedure
Procedure No.RC0410
Version No.3.2
Effective Date 6t21t2021
System Emergencies Distri bution Restriction
None
Reliabi I ity Coordi nator Actions
. Refer to RC West Operating Procedure RC0310 ltlitiqatinq SOL and IROL Exceedances.
o Declare a BES Emergency via a WECC-wide GMS message without delay (within 30
minutes),ll notifying all BAs, TOPs and Western RCs.
. Consider initiating a conference call if the condition affects multiple entities and if a
conference call will expedite coordination efforts.
o Coordinate mitigafion activities with affected TOPs and determine if an Operating
lnstruction is needed.
o Coordinate with BAs, TOPs and neighboring RCs that may be able to provide assisfance.
. lssue Operating lnstructions immediately, in accordance with Section 3.4: Operating
lnstructions, and Section 3.5: Load Shedding lnstructions.
. Monitor system conditions to determine if the instructed actions were implemented, and
whether the transmission Emergency will be resolved in a timely manner.
. lssue additional Operating lnstructions if needed.
o lssue notification to all BAs, TOPs and Western RCs once Emergency condition has been
mitigated and the system is stable via a WECC-wide GMS message.
. Log a summary of all communications and acfions.
3.3. Extreme Weather Emergencies
BAs and TOPs are expected to have Operating Plans (reviewed by the RC entity) that address the
reliability impacts of extreme weather in their area. They are also required to notify the RC operator
in Real-time when experiencing such an Emergency.12 Extreme weather Emergencies may include,
but are not limited to:
o Unanticipated high loading due to high or low temperatures,
o Wind/rain storms,
. Thunderstorms,
o Tsunamis,
o Hurricanes,
o Floods,
. Snow, and
. GMDs (See RC West Operating Procedure RC0430 GIVD Operatinq Plan).
1r EOP-011-1 R5.
12 EOP-011-1 R1.2.6, P2.2.9 (applicable to TOP and BA respectively)
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$ Colifornio ISO RC West Reliability
Coordinator
Procedure
Procedure No.RC0410
Version No.3.2
Effective Date 612112021
System Emergencies Distribution Restriction
None
When the RC operator receives a notification from a BA or TOP of an Emergency due to extreme
weather:
Rel iabil ity Coordinator Actions
o lssue an alert without delay to all impacted entities, but no longer than within 30 minutes.l3
o Notify all BAs and TOPs in the RC Area and neighboring RCs via GMS.
o Actively evaluate system conditions and determine mitigation options in coordination with
the affected BAs/TOPs. BA/TOP Operating Plans include (but not limited to) mitigation
optionsla such as:
o Cancelling or recalling transmission and generation outages,
o Reconfiguring transmission system,
o Re-dispatching generation,
o Shedding operator-controlled manual load that minimizes overlap with automatic load
shedding, and is capable of being implemented in a timeframe for mitigating the
Emergency,
o Requesting EEAs (Refer to Section 3.1: Capacity and Energy Emergencies),
o Managing generation to address capability and availability, fuel and inventory concerns,
fuel and switching capabilities, and environmental constraints,
o Submitting public appeals for voluntary load reductions,
o Requesting government agencies to implement their programs to achieve necessary
energy reductions,
o lnstructing a reduction of internal utility energy use, and
o Using interruptible load, curtailable load and demand response.o Refer to Section 0:
o Transmission System Emergencies if the weather Emergency is affecting the transmission
system.
. Refer to Section 3.1: Capacity and Energy Emergencies if the weather Emergency
creates capacity or energy issues.
o Monitor weather and forecasf tools to determine the effect of current and projected
conditions.
o Coordinate mitigaffon activities with affected BAs and TOPs and determine if an Operating
lnstruction is needed.
. Issue Operating lnstructions immediately, in accordance with Section 3.4: Operating
lnstructions, and Section 3.5: Load Shedding lnstructions.
13 EOP-011-1 R5.
'r1 EOP-01 1-'l R1.2 (applicable to TOP)
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10
!) Colifornio ISO RC West Reliability
Coordinator
Procedure
Procedure No.RC0410
Version No.3.2
Effective Date 612112021
System Emergencies Distribution Restriction
None
Reliabil ity Coordinator Actions
a
a
lssue notification to all impacted entities when the Emergency condition has been mitigated
and the system is back to normal:
o Notify all BAs and TOPs in the RC Area and neighboring RCs via GMS.
Log a summary of all communications and actions.
3.4. Operating lnstructions
During system Emergencies, the RC operator will actively evaluate system conditions, coordinate
mitigation activities with the affected BAs/TOPs and determine if there is a need to issue an Operating
lnstruction.
During a system Emergency, take the following actions
Reliability Coordi nator Actions
. Actively evaluate system conditions and determine possible mitigation options
o Coordinate with affected BNTOP to determine if the potential mitigation is viable.
o lf not, advise the BA/TOP of alternate or additional mitigation options.
o Evaluate the mitigation in progress to determine if the Emergency condition will be resolved
in a timely manner.
o lssue an Operating lnstruction without delay if the actions being taken are not adequate or
will not resolve the condition in a timely manner (Refer to RC West Operating Procedure
RCO1 1 0 Communications Protocols
o lf load shedding is required, refer to Section 3.5 - Load Shedding .
o Monitor system conditions to determine if the instructed actions were implemented and
whether the issues will be resolved in a timely manner.
. lssue additional Operating lnstructions if needed.
. Log a summary of all communications and acfions.
\
3.5. Load Shedding lnstructions
Load shedding should be considered a last resort to mitigate reliability issues that occur in Realtime.
All appropriate mitigation options should first be explored as time allows, including timely demand-
side management or load transfer, before issuing an Operating lnstruction to shed firm load. However,
during Emergency situations or during situations or events with the potential to result in Adverse
Reliability lmpact, the RC operator may determine that other mitigation actions will not be adequate
or would not resolve the issue in a timely manner. ln such cases, the RC operator should consider
issuing an Operating lnstruction to shed firm load.
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11
@ Colif"rnio ISO RC West Reliability
Coordinator
Procedure
Procedure No.RC0410
Version No.3.2
Effective Date 6t2112021
System Emergencies Distribution Restriction :
None
3.5.1. Situations that May Require Load Shedding
The RC operator should consider issuing an Operating lnstruction to shed load, when:
o A single or credible multiple Contingency will result in cascading outages, instability or voltage
collapse,
o An IROL exceedance is unlikely to be mitigated within 30 minutes or Tv,
o Potential Adverse Reliability lmpact due to generation/load imbalance caused by large
sustained ACE or frequency excursion, EEA, etc., or
o Following Realtime Assessment, it is unclear whether the system can sustain the next single
or credible multiple Contingency.
When the RC operator determines that one of the above Emergency conditions exists and load
shedding is being considered as an option:
3.5.2. When Load Shedding lnstruction May Not Be Viable
Generally, an Operating lnstruction to shed firm load may not be viable, when:
o The reliability issue can be mitigated in a timely manner using other mitigation actions.
o Shedding firm load will violate safety, equipment, regulatory or statutory requirements.
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12
Reliability Coordinator Actions
. Perform Real-time Assessmenfs in collaboration with the RTOEto validate the reliability
issue, if time allows.
o Gonfirm results with the affected BAs, TOPs and neighboring RCs.
o Operate conseruativelyif there is disagreement in study results between entities
o lf there is disagreement with a neighboring RC on the IROL or Tv for a shared facility,
operate to most limiting IROL or Tv.1s
o Discuss mitigation options with the affected BAs/TOPs and determine if those options can
resolve the issue in a timely manner
o Evaluate effectiveness of mitigation in progress to determine if the condition will be resolved
in timely manner
o Determine whether post-Contingency automatic or manual mitigation actions are available
or acceptable
o lssue an Operating lnstruction to shed load, if other mitigation actions will not resolve the
issue in a timely manner (Refer to RC West Operating Procedure RC0110 Communications
Protocols).
o Log a summary of all communications and acfibns.
ls lRo-009-2 R4.
@ C"lifornio ISO RC West Reliability
Coordinator
Procedure
Procedure No.RC0410
Version No.3.2
Effective Date 612112021
System Emergencies Distribution Restriction
None
o A load shed instruction cannot be physically implemented.
o Studies show that the risk to the system will be contained within a defined area.
. Load at risk is not sufficiently more than the load that would have to be shed pre-Contingency
3.6. Event Reporting
Certain BES Emergencies such as IROL violations, system separation (islanding), firm load shedding,
etc., require filing a NERC EOP-004 or a DOE OE-417 report. The RC operator will ensure that the
appropriate internal parties are notified to ensure that the proper reports are submitted.
Rel iability Goord i nator Actions
a Notify internal CAISO Emergency Response Coordinator of the BES Emergency in
accordance with RC West Operating Procedure RC-0420 Event Reportinq.
3.7. BA and TOP EOP-011 Plan Submissions and Review
The CAISO Operations Compliance team shallwork in conjunction with the RC to facilitate reviews
of the Emergency Operating Plan(s) submitted by BAs and TOPs.16
The EOP-011 plans can be submitted to RC West each time the plan(s) are updated. RC West does
not have an annual or periodic update requirement for EOP-011 plans.
The Plan Review Submissions library on the RC West secure website shall be used by the BAs and
TOPs to upload Emergency Operating Plan(s) for RC review. The BAs and TOPs shall upload the
plan document(s)with a completed RC0410A EOP-011 Plan Review Checklist.
Within 30 calendar days of receipt, RC West shall:
o Review each submitted Operating Plan(s) on the basis of compatibility and inter-dependencywith
other BAs' and TOPs' Operating Plans,
o Review each submitted Operating Plan(s) for coordination to avoid risk to Wide Area reliability,
and
. Notify each BA and TOP of the results of its review, specifying any time frame for resubmittal of
its Operating Plan(s) if revisions are identified.
Each TOP and BA shall address any reliability risks identified by the RC West and resubmit its
Operating Plan(s) to RC West within the specified time period.
Upon RC West's completion of the review process, the RC will post a review letter to the secure site
and notify the submitting entity.
16 EOP-011-1 R3, R3.1 and sub requirements
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13
'ap Colif"rnio ISO RC West Reliability
Coordinator
Procedure
Procedure No.RC0410
Version No.3.2
Effective Date 612112021
System Emergencies Distribution Restriction
None
4. Supporti ng lnformation
Ope rational Iy Affected Parties
Shared with the Public and AESO, BCRC, SPP RC and RC West BAs and TOPs
References
NERC Requirements COM-002-4; EOP-011-1 R3, R5, R6; IRO-009-2 R2, R3, R4;
tRo-o14-3.
BA/TOP Operating Procedure
RC West Operating Procedures RCO1 1 0 Communications Protocols
RC0310 tMitiqatinq SOL and IROL Exceedances
RC0420 Event Reportinq
RC0430 GIVD Operatinq Plan
RC0460 Reliability Coordinator Area Restoration Plan
Definitions
The following terms capitalized in this Operating Procedure are in accordance with the NERC
Glossary, and/or othenruise when used are as defined below:
Term Description
Emergency or BES
Emergency
Any abnormal system condition that requires automatic or
immediate manual action to prevent or limit the failure of
transmission facilities or generation supply that could adversely
affect the reliability of the Bulk Electric System.
Adverse Reliability lmpact
The impact of an event that results in frequency-related
instability; unplanned tripping of load or generation; or
uncontrolled separation or cascading outages that affects a
widespread area of the lnterconnection.
Extraord inary Conti ngency
Shall have the meaning set out in Excuse of Performance,
section B.4.c.language in section 8.4.c:
Means any act of God, actions by a non-affiliated third party,
labor disturbance, act of the public enemy, war, insurrection, riot,
fire, storm or flood, earthquake, explosion, accident to or
breakage, failure or malfunction of machinery or equipment, or
any other cause beyond the Reliability Entity's reasonable
control; provided that prudent industry standards (e.9.
maintenance. desiqn. operation) have been emploved: and
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$ Cotifornio ISO RC West Reliability
Coordinator
Procedure
Procedure No.RC0410
Version No.3.2
Effective Date 612112021
System Emergencies Distribution Restriction
None
Term Description
provided further that no act or cause shall be considered an
Extraordinary Contingency if such act or cause results in any
contingency contemplated in any WECC Reliability Standard
(e.9., the "Most Severe Single Contingency" as defined in the
WECC Reliability Criteria or any lesser contingency).
System Operating Limit
(soL)
The value (such as MW, Mvar, amperes, frequency or volts) that
satisfies the most limiting of the prescribed operating criteria for a
specified system configuration to ensure operation within
acceptable reliability criteria. System Operating Limits are based
upon certain operating criteria. These include, but are not limited
to:. Facility Ratings (applicable pre- and post-Contingency
Equipment Ratings or Facility Ratings),. Transient stability ratings (applicable pre- and post-
Contingency stability limits),o Voltage stability ratings (applicable pre- and post-
Contingency voltage stability), and
r System voltage limits (applicable pre- and post-
Contingency voltage limits).
I nterconnection Reliability
Operating Limit (IROL)
A System Operating Limit that, if violated, could lead to
instability, uncontrolled separation, or Cascading outages that
adversely impact the reliability of the Bulk Electric System.
Contingency Reserve
The provision of capacity that may be deployed by the Balancing
Authority to respond to a Balancing Contingency Event and other
contingency requirements (such as Energy Emergency Alerts as
specified in the associated EOP standard). A Balancing Authority
may include in its restoration of Contingency Reserve readiness
to reduce Firm Demand and include it if, and only if, the
Balancing Authority:
. ls experiencing a Reliability Coordinator declared Energy
Emergency Alert level, and is utilizing its Contingency
Reserve to mitigate an operating emergency in accordance
with its emergency Operating Plan, or
o ls utilizing its Contingency Reserve to mitigate an
operating emergency in accordance with its emergency
Operating Plan.
Reliability Coordinator (RC)
Area
The collection of generation, transmission, and loads within the
boundaries of the Reliability Coordinator. lts boundary coincides
with one or more Balancing Authority Areas.
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15
$ Colif"rnio ISO RC West Reliability
Coordinator
Procedure
Procedure No.RC0410
Version No.3.2
Effective Date 612112021
System Emergencies Distribution Restriction
None
Term Description
Capacity Emergency
A capacity emergency exists when a Balancing Authority Area's
operating capacity, plus firm purchases from other systems, to
the extent available or limited by transfer capability, is
inadequate to meet its demand plus its regulating requirements.
Cascading
The uncontrolled successive loss of System Elements triggered
by an incident at any location. Cascading results in widespread
electric service interruption that cannot be restrained from
sequentially spreading beyond an area predetermined by
studies.
Contingency
The unexpected failure or outage of a system component, such
as a generator, transmission line, circuit breaker, switch or other
electrical element.
Energy Emergency
A condition when a Load-Serving Entity or Balancing Authority
has exhausted all other resource options and can no longer meet
its expected Load obligations.
Version History
Version Change Date
1.0 Approved by Steering Committee 9126118
1.1 Section 3.3: Corrected minor reference error 11120118
1.2 Added notification to market participants when declaring EEAs.
Removed references to RCIS in Section 3.2.
Added RC0410A to Appendix section.
4119119
2.0 Annual Review:
Section 3.3: Updated notification information and removed RCIS
as a form of notification for extreme weather only.
Section 3.7: Clarified plan submission requirements
Replaced CAISO RC with RC West and updated to RC West
logo. Minor grammar and format updates.
4t21120
3.0 Annual Review: Updated criteria for issuing EEAs in Section 3.1,
and clarified references to RC0210. Updated all RC West
procedure references and updated procedure review frequency
to "Annual". Approved by Real-Time Working Group (RTWG).
2104121
3.1 Added Section 3.1.1 for EEA Watch. Added EEA Watch
templates to Section 3.1.6. Clarified criteria and steps for RC
declaring a "BES Emergency" in Section 3.2. Minor format and
grammar updates. Reviewed and approved by the Real-Time
Workinq Group.
4115121
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When downloaded or printed, this document becomes UNCONTROLLED.
16
@ cotibrnio ISO i nC West Reliability
Goordinator
Procedure
Procedure No.RC0410
Version No.3.2
Effective Date 612112021
System Emergencies Distribution Restriction :
None
3.2 Section 3.1: Updates made related to EEA Watch based on
received feedback.
6121121
5. Periodic Review Procedure
Review Griteria & lncorporation of Ghanges
There are no specific review criteria identified for this document.
Frequency
Annual.
Appendix
RC0410A EOP-011 Plan Review Checklist
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When downloaded or printed, this document becornes UNCONTROLLED
17
BEFORE THE
IDAHO PUBLIC UTILITIES COMM]SSION
GASE NO. IPC-E-21-13
IDAHO POWER COMPANY
CONFIDENTIAL
REQUEST NO. 1
ATTAGHMENT NO.2
CONFIDENTIAL DOCUMENT SENT
SEPARATELY
BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
GASE NO. IPC-E-21-13
IDAHO POWER COMPANY
REQUEST NO. 1
ATTACHMENT NO.3
e Colifornio lS RC West
April8,2021
ldaho Power
Contact: Gary Slayton
The California ISO Reliability Coordinator has reviewed your EOP-011 Operating Plan, P3g!
Manaoement Procedures. effective 4/1 /2021 .
The plan was found to be compatible with the RC's plan and other inter-dependent Balancing
Authority and Transmission Operator Operating Plans.
Review of your Operating Plan by the RC West Reliability Coordinator does not signify or
equate to a determination of compliance with any applicable reliability standards which can only
be assured by a functional entity's Compliance Enforcement Authority.
Reviewed by: Olga Zvyagina, Lead Operations Compliance and lntegration Analyst
lf you have any questions, please feel free to contact us at [e-mail]
Thank you,
Operations Compliance & Controls Team
RC West
Califomia ISO Reliability Coordinator, 250 Outcropping Way, Folsom, CA 95630
BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
GASE NO. IPC.E.21.13
IDAHO POWER COMPANY
CONFIDENTIAL
REQUEST NO. 2
ATTACHMENT NO. 1
CONFIDENTIAL DOCUMENT SENT
SEPARATELY
BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
GASE NO. IPC-E-21-13
IDAHO POWER GOMPANY
CONFIDENTIAL
REQUEST NO.4
ATTACHMENT NO. 1
CONFIDENTIAL DOCUMENT SENT
SEPARATELY
BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
GASE NO. IPC-E-21-13
IDAHO POWER COMPANY
REQUEST NO.4
ATTAGHMENT NO.2
ldaho Power Company
Corporate Communications
Customer Communications
For example communications recently used to request that customers reduce use during peak hours, see the following
o News release
o Webpaqe
o Social media
o Customer email:
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vEi M, Accorrnt.
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