20220323PAC to Staff 1-11.pdf

Y ROCKY MOUNTAIN
HSIYEA,
RECEIVED
2022 MAR 23 PM 4:34
IDAHO PlJBLIC
UTILITIES COMMISSION
'1407 W North Temple, Suite 330
Salt Lake City, Utah 84116
March 23,2022
Jan Noriyuki
Idaho Public Utilities Commission
472W. Washington
Boise, ID 83702-5918
ian.noriyuki@nuc. idaho. eov (C)
RE ID PAC.E.22-04
IPUC Set I (l-11)
Please find enclosed Rocky Mountain Power's Responses to IPUC I't Set Data Requests l-8 and
l0-l l. The response to IPUC 9 will be provided separately. Also provided is Attachment
IPUC 5.
If you have any questions, please feel free to call me at [phone].
Sincerely,
--Jsl-J. Ted Weston
Manager, Regulation
Enclosures
PAC-E-22-03 / Rocky Mountain Power
March 23,2022
IPUC Data Request I
IPUC Data Request 1
Please describe how the Company provides notification of curtailment or
intemrption to state regulatory and reliability authorities. Please provide
supporting documentation and examples.
Response to IPUC Data Request 1
Any real time load curtailments related to Bulk Electic System (BES) elements
are communicated directly to the Reliability Coordinator (RC) via telephone or
the RC Grid Messaging System. PacifiCorp has not experienced any ofthese
events that required immediate notification to the RC. Distribution relayed
curtailments are not communicated to the RC.
Rocky Mountain Power (RIVP) has an automated notification system that sends
information to the Idaho Public Utilities Commission (IPUC) when outages
involve 200 or more customers and the outage exceeds one hour in duration.
Recordholder: Brent Roholt
Sponsor:Wade Skinner
PAC-E-22-03 / Rocky Mountain Power
March 23,2022
IPUC Data Request 2
IPUC Data Request 2
Please explain how customers wer€ notified of the proposed update to Electic
Service Regulation No. 13 and provide copies ofthe notifrcation.
Response to IPUC Data Request 2
The large industrial customer participated in contact negotiations with the
Company that resulted in the elimination of the System Integrity product from its
intemrptible contact. Other than minor housekeeping edits, the only change to
Electric Service Regulation No. 13 is to remove this large industrial customer
from the Stage I category as an interruptible customer load shed.
As stated in Regulation No. l3:
"Interruptible Loads - Large intemrptible customers with
allowable curtailment allotments are available for
emergency load curtailment and are the first to be utilized
when immediate system stabilization is required.
It should be noted that the amount of available capacity for
emergency load curtaitnent is negotiated in contactual
agreements and therefore subject to change per contract
renewals and negotiations."
Recordholder: Ted Weston
Sponsor:Wade Skinner
PAC-E-22-03 / Rocky Mountain Power
March 23,2022
IPUC Data Request 3
IPUC Data Request 3
Please explain how Demand Response participants were notified of the proposed
update to Electic Service Regulation No. 13. Please provide copies ofthe
notification.
Response to IPUC Data Request 3
Please refer to the Company's response to IPUC Data Request 2. The proposed
update only impacts one large indusfiial customer, There is no change for demand
response customers; they are still in Stage I of the curtailment plan.
Recordholder: Ted Weston
Sponsor:Wade Skinner
PAC-E-22-03 /Rocky Mountain Power
March 23,2022
IPUC Data Request 4
IPUC Data Request 4
Please describe how the Company provides notification of curtailment or
intemrption to customers and the public. Please provide copies of notifications
and/or examples.
Response to IPUC Data Request 4
As noted under the Operating Standards of Electic Service Regulation No. 13,
the purpose of this plan is for emergencies that threaten the integrity of the
electric system. The curtailment plan is employed by the Company to temporarily
intemrpt elecfiic service to its customers during emergencies and power
shortages. It is intended to provide equitable procedures for the curtailment of
power, minimize adverse impacts to essential services, and customers, while
maintain overall system reliability. The circumstances necessitating a reduction in
the demand or consumption of electricity in the short term will normally require
that immediate emergency action is taken and there may be no warning or
notification.
Recordholder:Ted Weston
Sponsor:Wade Skinner
PAC-E-2243 / Rocky Mountain Power
March 23,2022
IPUC DataRequest 5
IPUC Data Request 5
Has the Electic Service Regulation No. 13 Ctrtailment Plan for Electric Energy
been approved by RC WestRegional Reliability Coordinator? If so, please
pnrvide documentation of approval.
Response to IPUC Data Request 5
Please refer to Attachment IPUC 5 which provides a copy of the approval letter
from the RC We$ Regional Reliability Coordinator for the EOP-01I Opemating
Plan: PacifiCorp System Operation Operating Procedure SOL-POL{07 effective
April 15,2021.
Recordholder: Brent Roholt
Sponsor:Wade Skinner
e Colifornio ISO RC West
4t28t2021
PacifiCorp
Contact: Kelly Myers
The RC West Reliability Coordinator has reviewed your EOP-O11 Operating Plan: PacifiCorp
Systems Operation Operating Procedure SOL-POL-007, effective 41 1 512021 .
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, Operations Compliance and lntegration Analyst Lead
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
PAC-E-22-03 / Rocky Mountain Power
March 23,2022
IPUC Data Request 6
IPUC Data Request 6
Regarding Curtrailment Stages, Type of Curtailment please define "General Use
Customers" and "Residential Customers".
Response to IPUC Data Request 6
As described in Elecfic Service Regulation No. 2, a customer is an individual,
partnership, corporation, organization, governmental agency, municipality, or
other entity contacting with the Company for electic service. Residential
customers are customers for whom service is furnished for (l) domestic purposes
in single-family dwelling units; (2) aparfinents where each dwelling unit is
separately metered and billed; and (3) combined family dwelling units and
rooming houses where not more than four rooms are used for sleeping or living
quarters by persons not members of the customer's family.
For purposes of the Curtailment Plan, all other customers are General Use
customers, except customers with allowable curtailment contacts.
Recordholder: Ted Weston
Sponsor:Wade Skinner
PAC-E-22-03 / Rocky Mountain Power
March 23,2022
IPUC Data Request 7
IPUC Data Request 7
Please provide Block Rotation documentation to include:
(a) Documents and maps that define the blocks and their atfributes.
(b) Schedule documentation that displays "what day of the week and time of day
a curtailment event would affect each block".
Response to IPUC Data Request 7
(a) PacifiCorp does not have a map of the blocks, but has defined the blocks as
follows:
Block Load Megawatts (Mtf)
SCC OI 51.5
SCC 02 43.6
SCC 03 36.8
SCC 04 47.9
SCC 05 40.6
SCC 06 49.2
SCC 07 63
SCC 08 40.2
SCC 09 46.3
SCC IO 5 1.8
SCC II 44
SCC 12 47.2
SCC 13 77.8
SCC 14 42.s
SCC 15 74.9
SCC 16 47.7
SCC 17 65.2
SCC 18 44.9
SCC 19 37.1
SCC 20 38.2
SCC 2I 43.4
scc 22 49
(b) The Curtaihment Stages are not set by day of the week or time of day, rather it
would depend on need of system at time of curtailment and how the Company
could most efliciently meet the need.
PAC-E-22-03 / Rocky Mountain Power
March 23,2022
IPUC Data Request 7
Recordholder: Brent Roholt
Sponsor:Wade Skinner
PAC-E-22-03 / Rocky Mountain Power
March 23,2022
IPUC DataRequest 8
IPUC Data Request 8
Please explain how "facilities essential to ttre public welfare" are determined,
fiacked, updated, and notified?
Response to IPUC Data Request 8
Critical facilities are identified by type, e.g. hospitals, police and fre, sewer and
water teafrnent facilities, airports, military, etc. These critical facilities are
identified by location and electrical source in Rocky Mountain Power's (RlvP)
Outage Management System (OMS) and excluded from the blocks referenced in
the Company's response to IPUC Data Request 7.
Recordholder: Kent Newman
Sponsor:Wade Skinner
PAC-E-22-03 / Rocky Mountain Power
March 23,2022
IPUC DaaRequest l0
IPUC Data Request 10
Regarding Section V. Notifications and Actions, Stage 5: Emergency Load Shed
Crroups, please define uall intemal and extemal notifications' and what plan this
communication would be apart of.
Rosponse to IPUC Data Request 10
Crenerally, due to the quick r€qponse time required by emergency load shed events
no advance internal or external notifioations are provided. The Company will
provide intemal and extsmal updates as soon as time permits and information is
known.
Recodholder: Wade Skinner
Sponsor:Wade Skinner
PAC-E-22-03 / Rocky Mountain Power
March 23,2022
IPUC Data Request I I
IPUC Data Request 11
Regarding Section III. Curtailment Stages, in the stage description Estimated
Curtailment Percent has not been updated to reflect changes to Types of
Curtailment. Please explain how the Estimated Curtailment Percentages and the
accuracy of the estimates are calculated.
Response to IPUC Data Request 11
No change to the Estimated Curtailment Percent was necessary because the
demand-side management (DSM) programs still represent more than 5 percent of
PacifiCorp's Idaho service territory load.
The circumstances of the emergency that necessitate energy curtailment will
determine what actions are required by the Company. The amount of load shed
will depend on what circuits are impacted by the emergency and the load on those
circuits.
As noted in Section III - State curtailment directives apply to all retail loads
(emphasis added) served within the State of Idaho. The curtailment stages are
associated with increasing energy deficits. The circumstances necessitating a
reduction in the demand or consumption of electricity in the short term will
normally require that immediate emergency action is taken and there may be
no warning (emphasis added). Sudden equipment outages or loss of generation
could potentially lead directly to any curtailment stage without prior notice or
progression of the stages described.
Recordholder:Ted Weston
Sponsor:Wade Skinner