20151209Staff 11-35 to PAC.pdf

BRANDON KARPEN
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
(208) 334-03s7
IDAHO BAR NO. 7956
Street Address for Express Mail:
472 W , WASHINGTON
BOISE, IDAHO 83702-5918
Attomeys for the Commission Staff
IN THE MATTER OF THE APPLICATION OF
ROCKY MOUNTAIN POWER TO UPDATE
ELECTRIC SERVICE REGULATION NO. 13
CURTAILMENT PLAN FOR ELECTRIC
ENERGY.
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BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
CASE NO. PAC.E.I5.IO
SECOND PRODUCTION
REQUEST OF THE
COMMISSION STAFF
TO ROCKY MOUNTAIN
POWER
The Staff of the Idaho Public Utilities Commission, by and through its attorney of record,
Brandon Karpen, Deputy Attorney General, requests that Rocky Mountain Power provide the
following documents and information as soon as possible, but no later than WEDNSDAY,
DECEMBER 30, 2015.
This Production Request is to be considered as continuing, and Rocky Mountain Power is
requested to provide, by way of supplementary responses, additional documents that it or any
person acting on its behalf may later obtain that will augment the documents or information
produced.
Please provide answers to each question, supporting workpapers that provide detail or are
the source of information used in calculations, and the name, job title and telephone number of
the person preparing the documents. Please identify the name, job title, location and telephone
number of the record holder.
SECOND PRODUCTION REQUEST
TO ROCKY MOLINTAIN POWER I DECEMBER 9,2015
In addition to the written copies provided as response to the requests, please provide all
Excel and electronic files on CD with formulas activated.
REQUEST NO. 11: Please provide a copy of the stage-by-stage administrative
obligations and communications plan for the initiation of load curtailment when curtailment is
directed by the Idaho Public Utilities Commission. For example, Stage I - when the Company
will begin (or continue if communication has already begun) providing curtailment information
to Consumers and electricity service suppliers (e.g., Idaho Falls); through Stage 5 - when the
Company collaborates with the State to develop and implement the most effective methods for
securing the required load curtailment and to minimize the economic and human hardships.
REQUEST NO. 12: Please provide a copy of the most recently submitted emergency
load curtailment program plan(s), emergency energy supply distribution plan(s), and Incident
Action Plans submitted to the California Public Utilities Commission pursuant to California
Public Resources Code Section 25701.
REQUEST NO. 13: Please provide a copy of the most recently submitted emergency
load curtailment program plan(s), emergency energy supply distribution plan(s), and Incident
Action Plans submitted to the Oregon Public Utilities Commission pursuant to Oregon Revised
Statute Title 57, Chapter 757.
REQUEST NO. 14: Please provide the most recent review and approval of the financial
penalties provisions by the Oregon, Washington, and California Public Utilities Commissions.
Please provide examples of when and where financial penalties were applied in these other
States.
REQUEST NO. 15: Please explain what is meant by an "equitable" curtailment of
power in the Company's o'Curtailment Plan for Electric Energy" (Plan) (See Application,
Proposed Tariffs, First Revision of Sheet No. 13R.1).
SECOND PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER DECEMBER 9,2015
REQUEST NO. 16: Please provide specific examples of how the Company coordinates
"with appropriate agencies to provide options to lessen the impact to customers" (See
Application, Proposed Tariffs, Clean and Legislative, First Revision Sheet No. 13R.1, second
paragraph, sixth bullet).
REQUEST NO. 17: Please explain how Section V. Notifications and Actions of the
proposed Plan minimizes the impact of curtailment and complies with the factors listed under
Idaho $ 6l-532.
REQUEST NO. 18: Please explain how the Company reduces the impacts to customers
during planned outages. Please describe the Company's incident response in situations where
planned outages pose risks to public safety and may cause emergency response or recovery by
local entities.
REQUEST NO. 19: Please explain how the Company plans for electrical supplies that
can operate independently from the Company's distribution networks within the Company's
Idaho service territory (i.e., the Company's balanced area) during both planned and emergency
power outages and curtailments. Please include any partnerships or other ways the Company
acknowledges micro-grid or smart-grid projects in Idaho.
REQUEST NO. 20: Please explain if the Company's coordination to lessen impacts to
customers includes any mutual aid agreements. If so, please provide a complete list of such
agreements.
R-EQUEST NO.21: Please describe recent efforts the Company has taken to know
which Idaho distribution feeders serve essential services and provide copies of any associated
reports (See Application, Proposed Tariffs, Section IV. Initiation of Load Curtailment,
Minimization of Impact, First Revision of Sheet No. 13R.4). Please explain if the Company
coordinates with essential facilities or electricity service suppliers to lessen impacts of planned or
emergency power outages or curtailments to customers (See Application, Proposed Tariffs,
Clean and Legislative, First Revision Sheet No. 13R.4, seventh paragraph).
SECOND PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER DECEMBER 9,2015
REQUEST NO. 22: Please explain any operational parameters or equipment necessary
for the Company to avoid feeders serving essential services during rotational curtailments within
the Idaho service area(See Application, Proposed Tariffs, Section IV. Initiation of Load
Curtailment, Minimization of Impact, First Revision of Sheet No.13R.4), including situations
where planned outages or unexpected weather events create the need for load shedding (i.e., to
comply with the federal or regional reliability N-1 contingency requirements). Please provide
what steps are required for the Company to implement rotational curtailments that avoid these
types of feeders (i.e., operations, equipment, etc). Please list the steps according to the specific
feeders.
REQUEST NO. 23: Please provide a copy of the 2015 Goshen Sub-Transmission Five
Year Study including the "Problems and Future Recommendations." Please describe how the
Company's Idaho Service Quality Review findings were was addressed or incorporated in the
2015 Goshen Study (i.e., service quality goals, reductions to the numbers and duration of outages
due to extreme weather, etc.). Please explain how load curtailment planning and the Company's
minimization of impact on communities were addressed in the 2015 Goshen Study.
REQUEST NO.24: The following pertains to the Block Rotation section of the
Company's Proposed Tariffs, Sheet No. 13R.4:
L Please explain whether the block rotation applies to transmission lines, as well as
distribution feeders.
Please provide a detailed explanation of the Company's ability to shed loads for
two hour rotational curtailments for circuits that contain either distribution or
transmission lines located within Idaho (i.e., manually or using SCADA control of
circuits) for load blocks less than 100 MW.
Please describe system modifications necessary for two hour rotational
curtailments of each of the circuits operated by the Company within Idaho,
regardless of load block size.
SECOND PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER
2.
3.
DECEMBER 9,2015
REQUEST NO.25: The Company states that it's "incident management strategy for an
energy emergency is consistent with the National Incident Management System and Incident
Command System" (See Application, Proposed Tariffs, Clean and Legislative, First Revision
Sheet No. 13R.5, Section V., second paragraph). Please provide a list of Company staff
qualified to serve as Incident Commanders within Idaho and provide their current certifications,
completed NIMS training courses and dates, and other documentation of qualifications.
REQUEST NO.26: Please describe the activities the Company has taken to incorporate
the National Incident Management System guidelines and associated National Planning
Frameworksl to coordinate, plan, and interact across the various levels of government and others
prior to and during emergency response. Example activities may include plan development,
table top exercises, etc.
REQUEST NO.27: Please provide a copy of the Company's "steady state protection
process" and the Company's "protection escalation decision process," as described in the 2014
National Protection Framework,2
REQUEST NO.28: Please provide an example Incident Action Plan for when the
Company implements rotating outages with the associated Incident Command System (ICS)
forms including, but not limited to, ICS-201 ,ICS-202,IC3-203, ICS-204, ICS-205, ICS-205A,
ICS-206, ICS-214, Annex Documents, Maps, Weather, and Credentials. Please explain how the
Company provides Incident Action Plans to electricity service suppliers, and other emergency
planning and response partners.
REQUEST NO. 29: Please provide examples of how the Company adheres to the intent
of the National Preparedness Framework,3 including a description of the methods the Company
utilizes to report and notify the Idaho Emergency Section Function (ESF) #12 (energy)
coordinator and other emergency operations contacts, and provide specific examples where the
' Available at: http:/lrvrvrv.lonra.gov/nationalJ:lanning-ltarnervorks, access l2l0l/2015.
2 Available at: http:,//u,rvw.fbnra.tov,/national-protection-fiamewol'k-0, accessed l2l0ll20l5.
3 Available at: htto;//,'vwlv.fbma.sovinational-prevention-fiamework, accessed 1210112015.
SECOND PRODUCTION REQUEST
TO ROCKY MOLINTAIN POWER 5 DECEMBER 9,2075
Company has released planned outage information, situation reports, and/or potential energy
emergency alerts to emergency planning and response partners in Idaho.
REQUEST NO.30: In reference to the Company's Incident Response and Recovery
Plan (IRRP) provided in Confidential Attachment IPUC 1, please provide the version number
and date. Please provide what prompted the Company's update to the most recent IRRP and
what factors will prompt future updates. Please explain if the Company documents changes
made to the IRRP for each version. If so, please provide a copy of the changes to the IRRP.
REQUEST NO.31: In reference to the responsibility of the Information Officer as
described at the bottom of page 8 of 36 in the Company's IRRP, please provide: (1) a detailed
description of the Joint Information System; (2) a copy of an example Joint Information System
plan; (3) any associated handbooks on Joint Information System operations; (4) the current list of
key internal and external stakeholders for the Idaho service area; and (5) all of the emergency
communications platforms utilized by the Company in order to alert local emergency response
entities.
REQUEST NO.32: In reference to Stakeholder Management - Commission
Notifications provided on page 9 of 36 in the Company's IRRP, please provide a detailed
description of the thresholds, required communication methods, and copies of notification
agreements for the jurisdictions served in Oregon, Washington, Califomia, Utah, Wyoming, and
Idaho.
REQUEST NO. 33: Please provide a narrative of the purpose for the Company's
"Large-Scale Outage Information" (i.e., https://lvww.piicilicrrorver.net/ed/po.html and
https://r.l"vr."w.rockymountainporver.net/ed/po.html). Please also provide copies of the associated
orders, rules, or requirements for online outage reporting and publication of outage information
issued since 2000 for each State with load served by the Company.
SECOND PRODUCTION REQUEST
TO ROCKY MOLINTATN POWER DECEMBER 9,2015
REQUEST NO. 34: Please explain the Company's involvement in the development of
the Peak RC's Enhanced Curtailment Calculator. Please indicate how the Company plans to
utilize the ECC in the future. If the Company does not plan to utilize the ECC, please explain
why not.
REQUEST NO. 35: Please provide a final list of participants and their respective roles
in the recent GridEx III exercise, copies of feedback and other input to Peak RC, WECC, NERC
and others, and any 'lessons learned' that are Company-speciflrc. Please explain if the
Company's leadership participate in either the exercise or in any discussions held during the
second day of the exercise where interagency'lessons learned'where developed. If so, please
provide a brief narrative of the Company's involvement, action items to strengthen the
Company's preparedness, and potential level of future involvement in national-scale energy
emergency response exercises (i.e., GridEx IV, etc.).
DATED at Boise,Idaho, this (Lkurof Decemb er2015.
Technical Staff: Johanna Bell (1 l-35)
i:umisc:prodreq/pace I 5. I 0bkmljb prod req 2
SECOND PRODUCTION REQUEST
TO ROCKY MOLINTAIN POWER
Deputy Attorney General
DECEMBER 9,2015
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 9ft DAY OF DECEMBER 2015,
SERVED THE FOREGOING SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF TO ROCKY MOUNTAIN POWER, IN CASE
NO. PAC-E-15.I0, BY MAILING A COPY THEREOF, POSTAGE PREPAID, TO
THE FOLLOWING:
TED WESTON
ID REG AFFAIRS MANAGER
ROCKY MOUNTAIN POWER
2OI S MAIN ST STE 23OO
SALT LAKE CITY UT 84I1I
E-MAIL: [e-mail]
DATA REQUEST RESPONSE CENTER
E-MAIL ONLY:
datarequest@pacifi corp. com
WONNE HOGLE
ROCKY MOUNTAIN POWER
2OI S MAIN ST STE 23OO
SALT LAKE CITY UT 8411I
E-MAIL: [e-mail]
CERTIFICATE OF SERVICE