20151230PAC to Staff 11-35.pdf

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ROCKY MOUNTAIN isrS 3tC 30 AH 8: 33HP,yy.Ek"lDp-li.] pllF;j ii.l 1407W NorthTemple, Suite330
UTlLli If S-COrvil,li$SiOil Salt Lake city, Utah 84116
December 29,2015
Jean Jewell
Idaho Public Utilities Commission
472W. Washington
Boise,ID 83702-5918
iean..i [e-mail]. gov (C)
RE: tD PAC-E-I5-10
IPUC 2nd Set Data Request (11-35)
Please find enclosed Rocky Mountain Power's Responses to IPUC Data Requests l1-35. Also
provided is Attachment IPUC 13. Provided on the enclosed Confidential CD are Confidential
Attachments IPUC 23,28,31 <l-2),32 -(1-5), and 35. We will send the Attorney Attestation
tomorrow Wednesday, December 3A, 201 5.
If you have any questions, please feel free to call me at [phone].
Sincerely,
J Tn Dr.4e^ I pr-l
J. Ted Weston
Manager, Regulation
PAC-E-15-10 / Rocky Mountain Power
December 29,2015
IPUC Data Request 11
IPUC Data Request 1L
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 ldaho 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.
Response to IPUC Data Request 11
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 is included in the first revision of 13R.5. It has been, and
will always be the Company's intent to communicate as much factual infbrmation
as possible during an event. These events can be dynamic and the need for
curtailment can increase and decrease complicating the communications process.
SECTION V. NOTIFICATIONS AND ACTIONS (included below), spells out
the communications elements of the plan including a listing of the external
stakeholders that will receive the information.
SECTION V. NOTIFICATIONS AND ACTIONS
Throughout the curtailment period, the Company will provide customers and
extemal State and regulatory stakeholders with as much information as possible
utilizing established processes and protocols. The Company's incident
management strategy for an energy emergency is consistent with the National
Incident Management System and Incident Command System, and provides
effective coordination through:
o Procedures that allow system and field operations to focus on critical
functional responsibilities ;e Providing pertinent information to internal and external stakeholders,
customers, regulators, media outlets, etc:o Flexible response to changing circumstances, special customer needs and
emergencies.
Stage 1: Interruptible Loads and Demand Side Management
The Company would not normally contact the public or news media when it
exercises options under intemrptible contract provisions and demand side
management programs.
Stage 2: Public Appeal for Conservation
At the Company's discretion, a public appeal for voluntary energy conservation
may be issued through media outlets, social media platforms, and automated
PAC-E-I5-10 / Rocky Mountain Power
December 29,2015
IPUC Data Request 11
outbound calling of customers requesting voluntary curtailment of nonessential
uses. Additionally, the Company will initiate curtailment of all nonessential
Company use, request curtailment of nonessential use by governmental agencies
and institutions at all levels, request voluntary curtailment of nonessential use in
all large buildings, and direct specific requests to major use customers for
voluntary curtailment of nonessential use.
If additional curtailment is required the Company will intensify its request to the
public, including requests to curtail less-essential uses, and notice that if
curtailment does not occur, mandatory curtailment may be necessary by utilizing
block rotation methods.
Stage 3: Peak Load Curtailment
Prior to any rotating outages, the Company, to the best of its ability will contact
key extemal stakeholders to inform them of the situation. To the extent possible,
areas targeted for rotating outages may be disclosed at this time, together with
some estimate of how long the outages will be necessary. The magnitude of the
event will dictate the administrative level to which external notifications will be
made.
Key extemal stakeholders include, but are not limited to:o Govemor's office. Utility Commissionso State energy/emergency response officialso Legislativeleadership. Key customer accounts
Stage 4: Block Load Curtailment
In addition to the actions above, to the extent possible, customers in the areas
targeted for rotating outages will be notified as soon as practicable and provided
with an estimate of the time their block will be curtailed and the expected
duration.
Stage 5: Emergency Load Shed Groups
Generally, no advance notice of an event necessitating emergency load shed is
available. Therefore, it is to be expected that all internal and external notifications
will occur as soon as information is known.
Recordholder: Teresa Connors-Perez
Sponsor: Teresa Connors-Perez
PAC-E-I5-10 / Rocky Mountain Power
December 29,2015
IPUC Data Request 12
IPUC Data Request 12
Please provide a copy of the most recently submitted emergency load curtailment
program plan(s), emergency energy supply distribution plan(s), and lncident
Action Plans submitted to the California Public Utilities Commission pursuant to
California Public Resources Code Section 257 0l .
Response to IPUC Data Request 12
The Company does not submit any of the plans referenced in the question on a
regular basis. The Company has been unable to locate copies of the original frling
that was made in response to Califomia Public Resources Code SectionZl7}l,
which may have happened in approximately 1975.
Recordholder: To Be Determined
Sponsor: To Be Determined
PAC-E-I5-10 / Rocky Mountain Power
December 29,2015
IPUC Data Request l3
IPUC Data Request 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.
Response to IPUC Data Request 13
Please refer to Attachment IPUC 1 3 for a copy of Oregon Rule 15, Curtailment
Plan for Electric Energy.
Recordholder: Betsy Watkins
Sponsor: To Be Determined
PAC-E-I5-10 i Rocky Mountain Power
December 29,2015
IPUC Data Request l4
IPUC Data Request 14
Please provide the most recent review and approval of the financial penalties
provisions by the Oregon, Washington, and Califomia Public Utilities
Commissions. Please provide examples of when and where financial penalties
were applied in these other States.
Response to IPUC Data Request 14
Any financial penalty provisions in these states contained in current tariffs have
not been reviewed or applied in curuent records.
Recordholder: Not applicable
Sponsor: To Be Determined
PAC-E-I5-10 / Rocky Mountain Power
December 29,2015
IPUC Data Request 15
IPUC Data Request 15
Please explain what is meant by an "equitable" curtailment of power in the
Company's "Curtailment Plan for Electric Energy" (Plan) (See Application,
Proposed Tariffs, First Revision of Sheet No. l3R.1).
Response to IPUC Data Request 15
The term o'equitable" curtailment of power in the Company's 'oCurtailment Plan
for Electric Energy" plan is meant to refer to the Company's intent to curtail load
on as broad a scale as possible and to rotate the load blocks required to remedy
the electrical issue or mandate causing the load to be curtailed. It is the
Company's intent to curtail load in this fashion so that customers in certain
geographic locations or sourced from SCADA controlled circuits are not curtailed
more often or for longer durations than other customers.
Recordholder: Teresa Connors-Perez
Sponsor: Teresa Connors-Perez
PAC-E-I5-10 / Rocky Mountain Power
December 29,2015
IPUC DataRequest 16
IPUC Data Request 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.
l3R.l, second paragraph, sixth bullet).
Response to IPUC Data Request 16
Per the Company's Customer Guarantees program as filed in Regulation 25,
planned outage notifications are delivered to impacted customers at least 48 hours
prior to the beginning of the planned outage time. If possible, large planned
outages affecting entire communities will be communicated with more advanced
notice. Each community in our service territory is assigned a customer and
community manager to act as the liaison to address any issues brought forward by
city leadership.
If scheduling allows, outage times are often scheduled to accommodate the
special needs of the affected community, examples of these special needs could
be limitations with water, sewer or special city events. tn addition, and if
scheduling allows, outages impacting large industrial and commercial customers
are scheduled to coincide with their plan maintenance activities when possible. As
an example, the Company coordinates planned outages with Monsanto in Soda
Springs, Idaho to coincide with their internal maintenance schedules to lessen the
impact.
For load curtailment events, efforts that include appropriate agencies are
undertaken to reduce the impact to customers. Examples of these efforts could
include re-configuration of the electrical network or working with inter-connected
entities to change relay settings or utilize emergency ratings for transmission lines
and transfofiners.
Recordholder: Teresa Connors-Perez
Sponsor: Teresa Connors-Perez
PAC-E-I5-10 / Rocky Mountain Power
December 29,2015
IPUC Data Request 17
IPUC Data Request 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 $ 61-532.
Response to IPUC Data Request 17
In the Company's response each of the Idaho $ 61-532 factors will be addressed
individually:
Factor (a) - the consistency of the plan public health, safety and welfare:
As documented in First Revision of Sheet No. 13R.4, the minimization of impact
paragraph describes the type of facilities excluded from curtailment whenever
possible, in the Company's effort to consider public health, safety and welfare.
Factor O) - the technical feasibility of the implementation of the plan:
The company considers the plan technically feasible having implemented it on a
number of occasions including the Goshen Substation event in December of 2013.
Factor (c) - the effectiveness with which the plan minimizes the impact of any
curtailment:
The impact of a curtailment event is determined on a case-by-case basis in terms
of the amount of load reduction required to resolve an electrical issue or fulfill a
mandate. The curtailment blocks included in the plan include geographic diversity
so that not one community or county in the same service territory is impacted to a
gleater extent than another.
Recordholder: Teresa Connors'Perez
Sponsor: Teresa Connors-Perez
PAC-E-I5-10 / Rocky Mountain Power
December 29,2015
IPUC DataRequest 18
IPUC Data Request 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.
Response to IPUC Data Request 18
Consistent the response to IPUC Data Request 16 and as scheduling allows, the
Company attempts to schedule planned outages to accommodate requests from
customers and agencies to a timeframe which creates the least impact. In addition,
the Company makes every effort to keep planned outages as short in duration as
possible by ensuring all materials, equipment and manpower is available to
complete the work prior to the outage.
The intent of the planned outage notification process and the customer and
community manager liaison role is to identiff situations where public safety or
emergency response and recovery by local entities may be at risk. Every measure
possible will be undertaken in these situations to mitigate these risks. These
measures may include installation of mobile substations, portable generators, or
installation of temporary facilities, if time allows.
Recordholder: Teresa Connors-Perez
Sponsor: Teresa Connors-Perez
PAC-E-15-10 / Rocky Mountain Power
December 29,2015
IPUC Data Request l9
IPUC Data Request 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 powff outages and curtailments. Please include any partnerships
or other ways the Company acknowledges micro-grid or smart-grid projects in
Idaho.
Response to IPUC Data Request 19
lnterconnection of electrical supplies that can operate independently from the
Company's distribution networks within the Company's Idaho service territory
are studied, designed, and constructed to operate safely upon loss ofservice from
the Company's distribution network. The Company currently has no micro-grid or
smart-grid projects connected to the system but the same considerations will
apply should these technologies emerge.
Recordholder: Teresa Connors-Perez
Sponsor: Teresa Connors-Perez
PAC-E-15-10 / Rocky Mountain Power
December 29,2015
IPUC Data Request 20
IPUC Data Request 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.
Response to IPUC Data Request 20
lt is unlikely that mutual aid assistance would be valuable to lessen the impacts of
planned outages or curtailment events. The Company can call upon mutual aid
assistance to lessen the impact of major outage events caused by severe weather
or other unforeseen long duration emergencies.
The Company is currently a party to the following mutual aid agreements:
l. Berkshire Hathaway Energy intemal mutual aid agreement
2. Western Region Mutual Assistance Group as lead by the Western Energy
Institute
3. Edison Electric Institute Mutual Assistance Agreement
Recordholder: Teresa Connors-Perez
Sponsor: Teresa Connors-Perez
PAC-E-I5-10 / Rocky Mountain Power
December 29,2015
IPUC Data Request 21
IPUC Data Request 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).
Response to IPUC Data Request 2l
In the past l8 months, the Company has conducted an extensive survey with
communities and organizations to identifr feeders that service essential services,
such as hospitals, police and fire departments, large sewage treatment plants,
radio stations with Emergency Broadcasting System (EBS) capability, large
airports, etc. Once these feeders were identified, the associated service
transformers were marked and identified in Company's mapping system as
critical loads with an associated level of criticality. There were no specific reports
associated with the survey and data entry.
As stated in IPUC Data Response 16, the Company utilizes the customer and
community managers to coordinate with essential facilities in their assigned
communities. The Company also coordinates all planned and emergency outages
with interconnected electricity service providers and attempts to lessen the impact
of the outage whenever possible.
Recordholder: Teresa Connors-Perez
Sponsor: Teresa Connors-Perez
PAC-E-15-10 / Rocky Mountain Power
December 29,2015
IPUC Data Request 22
IPUC Data Request22
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-l 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.
Response to IPUC Data Request22
The Company has identified distribution circuits containing essential services and
avoids curtailment to these circuits through use of 100MW rotational load
curtailment blocks. These rotational load curtailment blocks will be used in a
company-wide energy defi ciency.
In a localized energy deficiency, curtailment parameters are determined at the
time in need. Initial load curtailment is performed using SCADA and rotational
curtailment is then determined. Circuits serving essential services are not included
in the rotational load curtailment plan. Essential services include: hospitals, police
and fire departments, large sewage treatment plants, radio stations with
Emergency Broadcasting System (EBS) capability, large airports, etc.
Recordholder: Teresa Connors-Perez
Sponsor: TeresaConnors-Perez
PAC-E-15-1 0 1 Rocky Mountain Power
December 29,2015
IPUC Data Request 23
IPUC Data Request 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.
Response to IPUC Data Request 23
Findings in the Idaho Service Quality Review report were not considered when
preparing the Goshen, Idaho area sub-transmission system five-year study. These
two reports are prepared with different pu{poses in mind. An area sub-
transmission system five-year study is focused on identifiring transmission system
limitations, with options and recommendations to solve local system
reinforcements needed to serve load growth for the planned study timeframe, in
this case,2015 to 2019.
The 2015 Goshen study does not address curtailment planning. See responses to
IPUC Data Request 22 and IPUC Data Request 24 for company curtailment
planning methods.
Please refer to Confidential Attachment IPUC 23.
Recordholder: Teresa Connors-Perez
Sponsor: Teresa Connors-Perez
PAC-E-15-10 / Rocky Mountain Power
December 29,2015
IPUC Data Request 24
IPUC Data Request24
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.
2. 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.
3. 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.
Response to IPUC Data Request2{
Block rotation only applies to distribution feeders. Emergency load
curtailment blocks only include SCADA capability substations and
identifies both transmission and distribution feeders. This is designed as
such to quickly manage energy deficiencies that may cause reliability
concems in neighboring power utilities.
There is one block dedicated to Idaho that is less than 100MW. This block
is completely SCADA controlled and may be dissected to reduce the
amount of curtailment. The Company's ability to shed load is determined
day-of, based on extent of the energy deficiency and boundaries. The
initial load curtailment targets distribution circuits first. If needed,
transmission lines are targeted next to meet the curtailment amount due to
Iack of SCADA capability in outlying substations. The first rotation for
curtailment is determined for both SCADA and non-SCADA distribution
lines and personnel are dispatched to the non-SCADA substations.
No system modifications are needed, although installing SCADA in
substations helps with switching personnel challenges. Rotational
curtailment relies on both manual operation of circuit breakers at
substations and SCADA use; however, there are no rotational curtailments
designed to target a specified geographical area other than all of Rocky
Mountain Power serviced by Salt Lake Control Center. Rotational
curtailment exclusive to Idaho will take day-of planning to identify load
curtaihnent amount as well as boundaries of event.
Recordholder: Teresa Connors-Perez
Sponsor: Teresa Connors-Perez
1.
2.
3.
PAC-E-15-10 / Rocky Mountain Power
December 29,2015
IPUC Data Request 25
IPUC Data Request 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 [ncident Commanders
within ldaho and provide their current certifications, completed NIMS training
courses and dates, and other documentation of qualifications.
Response to IPUC Data Request 25
The company staff qualified to serve as Incident Commanders in Idaho are:
r Paul Radakovich - Rocky Mountain Power Vice President, Transmission
and Distribution Operations, Bachelor of Science in Electrical Engineering
Degree, 33 years of operations and engineering experience and extensive
experience serving as Incident Commander during actual events.o Kevin Freestone - Rocky Mountain Power, Director of Distribution
Operations, Bachelor of Science in Electrical Engineering Degree, 25
years of operations and engineering experience and extensive experience
serving in multiple Incident Command center roles including Incident
Commander, during actual events.
o Scott Derrick - Rocky Mountain Power, Director of Distribution
Operations, certified Joumeyman Lineman, 22 years of operations and
extensive experience serving in multiple lncident Command center roleso Dan Bodily - Rocky Mountain Power, Director of Distribution Operations,
certified Journeyman Lineman, 35 years of operations and extensive
experience serving in multiple lncident Command center roles
The company Disaster/Risk Planning Manager position is trained in National
Incident Management System (NIMS). It was not the company's intent to require
all personnel that fi1l incident command center roles to attend NIMS formal
training sessions. The company relies on the Disaster/Risk Planning Manager to
train personnel on company incident response and recovery plans that include
relevant NIMS information.
Recordholder: Teresa Connors-Perez
Sponsor: Teresa Connors-Perez
PAC-E-I5-10 / Rocky Mountain Power
December 29,2015
IPUC Data Request 26
IPUC Data Request 26
Please describe the activities the Company has taken to incorporate the National
Incident Management System guidelines and associated National Planning
Frameworks' to "oo.dinate, plan, and interact across the various levels of
govemment and others prior to and during emergency response. Example
activities may include plan development, table top exercises, etc.
Response to IPUC Data Request 26
The Company's emergency plans have been designed to follow the National
Incident Management System guidelines and associated National Planning Frame
works only in the organization and plan structure and do not necessarily include
one-for-one, mirrored processes. The plan was designed to ensure uniform
nomenclature, scalability, flexibility and to foster clear communication and
understanding between the Company's incident command and those of Federal
and State agencies during an actual emergency event.
Recordholder: Teresa Connors-Perez
Sponsor: Teresa Connors-Perez
' Available at: http.://www.fema.sov/nationql-plannins-frameworks, access l2/Ol/2015.
PAC-E-15-10 / Rocky Mountain Power
December 29,2015
IPUC Data Request 27
IPUC Data Request27
Please provide a copy of the Company's "steady state protection process" and the
Company's "protection escalation decision process," as described inthe2014
National Protection Framework,'
Response to IPUC Data Request2T
Per the response to IPUC Data Request 26, the Company's plan does not follow
verbatim the National Protection Framework in that we do not call out a "steady
state protection process" or "protection escalation decision process". The
Company Incident Response and Recovery Plan includes a Hazard and Threat
Summary section that is included below.
Hazard and Threat Summary
A crisis is any unexpected event or series ofevents, anticipated or underway, that
significantly impact and/or harm the company's operations, buildings, assetso
finances, personnel, image, reputation, or the environment. The acfual or potential
crisis results from both the event itself and the impacts and consequences that
result.
The table below shows potential hazardslthreats and their respective ranking score
derived through application of the FEMA Hazard,Impact, Risk and Vulnerability
Analysis (HIRV) Model.
Frequency: Historical incidence rate
(0 being erratic, 5 being recurrent)
Recovery: Length of recovery
(0 being immediate, 5 being beyond normal parameters)
Severity: Extent of impact to company assets, systems and delivery of service
(0 being none, 5 being catastrophic)
Magnitude: Depth of impact to essential operating and business functions
(0 being none,5 being company/platform wide)
I Available at: hftp://www.fema.eov/national-protection-framework-0, accessed l2lol/2015.
PAC-E-15-10 / Rocky Mountain Power
December 29,2015
IPUC Data Request 27
Hazard / Threat Rankine Factors Rank
Frequencv Recovery Severity Maenitude
Storms
Snow, wind, rain, ice,
lishtnins
4 I I 0 6
Fire
Wildland 2 1 2 0 5
Natural disasters
Floods (including
dam failures)I I 2 0 4
Landslides I I 2 0 4
Catastrophic
Earthquakes 0 5 5 5 15
Tornadoes 0 3 3 I 7
Pandemics
Infectious disease
outbreaks
0 1 I 2 4
Threats specifically
targeted at the
company
Bomb tfueats,
sabotage, cyber
attacks
1 2 aJ 7
Tenorist incidents
targeted outside the
company, but with
impact to the
company, personnel
and communiw
0 I 2 I 4
Assumptions:
Emergency planning requires commonly accepted set of operational conditions
that provide a foundation for establishing protocols and procedures. The
following statements reflect certain known facts and reasonable assumptions upon
which components of the plan are based.o An emergency incident may occur at ary time of the day or night,
weekend or holiday, with little or no waming.o The succession ofevents in an incident are not entirely predictable, hence,
published support and operational plans will serve only as a guide and
may require ad hoc modification in order to meet the requirements of the
event.
o Communication and exchange of information is one of the highest
priorities.
PAC-E-15-10 / Rocky Mountain Power
December 29,2015
IPUC Data Request 27
o Incidents occurring external or intemal to the company may intemrpt
critical utilities including water delivery, electrical power, natural gas,
telephone communications, microwave and repeater-based radio systems,
cellular telephones and information systems (intemeVintranet).
o Unique recovery operations may require expertise or equipment that is not
present day to day.
Recordholder: Teresa Connors-Perez
Sponsor: Teresa Connors-Perez
PAC-E-I5-10 / Rocky Mountain Power
December 29,2015
IPUC Data Request 28
IPUC Data Request 28
Please provide an example Incident Action PIan for when the Company
implements rotating outages with the associated Incident Command System (ICS)
forms including, but not limited to, ICS-201, ICS-202, ICS-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,
Response to IPUC Data Request 28
Per the response to IPUC Data Request 26, the Company's plan does not follow
the National Protection Framework in that we do not use the form templates
provided. For a sample form used to document activities during the activation of
the incident command center, please see the attached.
Please refer to Confidential Attachment IPUC 28.
Recordholder: Teresa Connors-Perez
Sponsor: Teresa Connors-Perez
PAC-E-I5-10 / Rocky Mountain Power
December 29,2015
IPUC Data Request 29
IPUC Data Request 29
Please provide examples of how the Company adheres to the intent of the
National Preparedness Framework,l 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 Company has released planned outage
information, situation reports, and/or potential energy emergency alerts to
emergency planning and response partners in Idaho.
Response to IPUC Data Requestl9
The company is eager to engage and participate 'ul'ith emergency operation plan
developments in Idaho to ensure our plans are properly coordinated.
The company would communicate with the Idaho Emergency Section Function
(ESF) #12 (energy) coordinator per the communications protocol in Section V. of
the Curtailment Plan for Electric Energy. As also stated in our response in IPUC
Data Request 31, the external stakeholders listed in the table below would receive
communications depending on the extent of the event and the need to coordinate
event response.
State Contact
state of ldaho
State of ldaho
State of ldaho
Stete of ldaho
State of ldeho
IDDEq
ID BHS
ID PUC
ID PUC
Red Aoss lD
Statewide
EmPrgency
Alert
The Company could not locate any specif,rc examples where the Company has
released planned outage information, situation reports, and"/or potential energy
emergency alerts to emergency planning and response partners in Idaho.
Recordholder: Teresa Connors-Perez
Sponsor: Teresa Connors-Perez
I Available at: http://www.ferna.gov/national-nrevention-framelvork, accessed l2/Ol/2015.
PAC-E-15-10 / Rocky Mountain Power
December 29,2015
IPUC Data Request 30
IPUC Data Request 30
In reference to the Company's Incident Response and Recovery Plan (IRRP)
provided in Confidential Attachment IPUC l, 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.
Response to IPUC Data Request 30
The Company's Incident Response and Recovery Plan (IRRP) version number
and date is IPUC: 7-2015. This is the first version of this document prepared in
response to the data requests in this docket PAC-E-15-10 First Production
Request of the Commission Staff to Rocky Mountain Power. Future updates could
be prompted by organizational changes, changes to NERC standards or to capture
lessons leamed from actual events. The Company does document the reason for
the plan revisions but not the actual changes. This is the first version of this
document and no changes have been made to date.
Recordholder: Teresa Connors-Perez
Sponsor: Teresa Connors-Perez
PAC-E-I5-10 / Rocky Mountain Power
December 29,2015
IPUC Data Request 31
IPUC Data Request 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: (l) a detailed
description of the Joint Information System; (2) a copy of an example Joint
Information System plan; (3) any associated handbooks on Joint lnformation
System operations; (4) the current list ofkey 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.
Response to IPUC Data Request 3l
(1) The joint information system can best be described as a process to ensure all
resources tasked with communicating information about an event are utilizing
the most current, accurate, and incident commander approved information.
The system also accommodates requests for information from external
stakeholders and works with the incident commander to fulfil these requests,
if possible.
(2) Other than the description given on pages 8 and 9 in the Company's IRRP,
there is no written plan to provide as an example of the joint information
system plan. Again, the joint information system is really a process used to
enslre message consistency and accuracy.
(3) The company does not have handbooks on the Joint lnformation System Plan.
(4) Please find attached lists of internal and external stakeholders for the Idaho
service area.
(5) A list of all potential emergency communications platforms utilized by the
company to alert local emergency response entities are:
a) email
b) cell phones
c) land line phones
d) text messaging
e) satellite phones
0 Government Emergency Telecommunication Service cards (GETS cards)
g) mobile radio
Please refer to:
Confidential Attachment IPUC 3 l-1.
Confidential Attachment IPUC 31-2.
Recordholder: Teresa Connors-Perez
Sponsor: Teresa Connors-Perez
PAC-E-15-10 / Rocky Mountain Power
December 29,2015
IPUC Data Request 32
IPUC Data Request 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, California, Utah,
Wyoming, and Idaho.
Response to IPUC Data Request 32
In California, commission notification requirements are identified in General
Order 166, Standard 12, Standards for Operation, Reliability, and Safety During
Emergencies and Disasters.
In Oregon, the notification requirement is stated in Oregon Administrative Rule
860-024-0050(1XbXD).
In Wyoming, notification requirements are identified in Public Service
Commission Rules, Chapter 3, Section 325, Additional Electric Utility Service
Interruption Reporting.
The Company is not aware of formal written agreements regarding incident
notification to commissions in Idaho, Utah, or Washington.
Notifications are made to the Idaho Public Utilities Commission as outlined in
Confidential Attachment IPUC 32-4.
Please refer to:o Confidential Attachment IPUC 32-1.o Confidential Attachment IPUC 32-2.o Confidential Attachment IPUC 32-3.o Confidential Attachment IPUC 32-4.o Confidential Attachment IPUC 32-5.
Recordholder: Teresa Connors-Perez
Sponsor: Teresa Connors-Perez
PAC-E-I5-10 / Rocky Mountain Power
December 29,2015
IPUC Data Request 33
IPUC Data Request 33
Please provide a narrative of the purpose for the Company's "Large-Scale Outage
Information" (i.e., https : //www.pacifi cpower. net/ed/po. html and
https://www.rockymountainpower.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.
Response to IPUC Data Request 33
The purpose of the large-scale outage information is to provide customers in each
state with information on larger outages in their area. Information is posted, at a
minimum, every 30 minutes. Typically outages affecting more than 500
customers are posted, but not all outages are listed. This feature was implemented
for customers in 2010 and was in response to customer requests for this type of
information. There are no associated orders, rules, or requirements associated
with this offering.
Recordholder: Teresa Connors-Perez
Sponsor: Teresa Connors-Perez
PAC-E-I5-10 / Rocky Mountain Power
December 29,2015
IPUC Data Request 34
IPUC Data Request 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.
Response to IPUC Data Request 34
PacifiCorp has been a participating member of the Enhanced Curtailment
Calculator task force since it was established in June 2014 and expects to use the
tool as provided by Peak RC for situational awareness; however, the tool is still in
the development process and has not been released for testing or training by the
member entities.
Teresa Connors-Perez
Teresa Connors-Perez
PAC-E-15-10 / Rocky Mountain Power
December 29,2015
IPUC Data Request 35
IPUC Data Request 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-specific. 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
leamed' 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.).
Response to IPUC Data Request 35
Please refer to Confidential Attachment IPUC 35.
Recordholder: Teresa Connors-Perez
Sponsor: Teresa Connors-Perez