20150720_4724.pdf

DECISION MEMORANDUM

TO: COMMISSIONER KJELLANDER
COMMISSIONER RAPER
COMMISSION SECRETARY COMMISSION STAFF
FROM: BRANDON KARPEN
DEPUTY ATTORNEY GENERAL
DATE: JULY 17, 2015
SUBJECT : APPLICATION TO UPDATE AND REVISE CURTAILMENT PLAN,
CASE NO. PAC-E-15-10
On June 25, 2015, PacifiCorp dba Rocky Mountain Power (“Rocky Mountain” or
“Company”) filed an Application seeking authority to update and revise its 1993 Curtailment
Plan. The Curtailment Plan sets out the actions that the Company will employ during periods
when it experiences energy shortages. Application at 2. According to the Company, the current
Curtailment Plan addresses only contingencies for long-term energy shortages, but does not
address short-term supply emergencies. Over the last 22 years, changes in technology, industry
practices, and increases in generation capacity have made the 1993 Curtailment Plan obsolete.
Rocky Mountain proposes to update the plan to include new provisions for load
reduction with demand-side management and emergency load shed groups, removal of financial
penalties, and clarification regarding what entity can initiate load curtailment. A. Shingleton
Direct at 2. The proposed plan covers a broader range of events that could lead to a load
curtailment situation, incorporates new curtailment sources, and addresses long- and short-term
supply emergencies. Id. at 2-5
THE APPLICATION
Rocky Mountain is a public utility engaged in the generation, transmission and
distribution of electricity. Rocky Mountain’s service area includes parts of southeastern Idaho.
In 1993, by Order of the Commission,1 Rocky Mountain adopted provisions relating to electric
service curtailment during periods of prolonged energy shortages. These provisions formed the
1 Case No. GNR-E-93-2, Order No. 25259.
DECISION MEMORANDUM 1

Curtailment Plan that Rocky Mountain filed with the Commission in 1993, which was the last
time the Company filed such a plan with the Commission.
Rocky Mountain claims the existing Curtailment Plan (the “1993 Plan”) is deficient
in addressing contingencies for short-term emergencies, and is also obsolete due to changes in
technology, new industry practices, and advanced generation capacity developed over the past 22
years. The Company proposes to modify the 1993 Plan to: “(a) include new provisions for load
reduction with demand-side management and emergency load shed groups; (b) remove financial
penalties [from the 1993 plan]; and (c) clarify the types of entities that can initiate load
curtailment.” Application at 2. The proposal also increases the range of activates that can
precipitate load curtailment activities. Id.
Rocky Mountain claims that the proposed plan combines elements of the Company
Emergency Management Plan filed in 2001, using the 1993 Plan as a starting point. The
Company claims that the updated plan will focus on “practical and actionable operational
activities the Company can initiate during emergencies to minimize adverse impacts to
consumers and restore system stability.” Id.
Rocky Mountain also proposed elimination of portions of the 1993 Plan that relate to
financial penalties and how curtailment is audited and tracked. Id. at 3. The Company argues
that the 1993 Plan’s inclusion of financial penalties is inappropriate in light of Commission
Order No. 25259, which “states [the Commission’s] preference that utilities not incorporate
monetary penalties within their respective plans.” Id. Finally, the proposed plan incorporates
new curtailment sources, “including DSM capabilities and interruptible customer load shed
programs.” Further, the proposed plan includes the ability for the Company to utilize block
rotation in scheduled two-hour periods during emergency periods.
Rocky Mountain has requested that this Application be processed under Modified
Procedure.
STAFF RECOMMENDATION
Staff recommends that the Commission issue a Notice of Application and set a 14-
day intervention deadline, and direct Staff to informally confer with the parties about scheduling.
Finally, Staff recommends the setting of an informal scheduling meeting take place once the
Notice of Parties has been issued.

DECISION MEMORANDUM 2
COMMISSION DECISION
Does the Commission wish to issue a Notice of Application, establish a 14-day
intervention deadline, and direct Staff to informally confer with the parties about scheduling?

_Brandon Karpen_______________________ Brandon Karpen Deputy Attorney General

M:PAC-E-15-10
DECISION MEMORANDUM 3