19930401Regional Curtailment Plan.pdf

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REGIONAL GURTAILMENT PLAN
FOR
ELEGTRIC ENERGY
Prepared by
Northwest Load Gurtailment Plan Task Force
May 22,1992
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PREFACE
BACKGROUND
The Regional Curtailment Plan for Electic Energy represents a comprehensive
revision of the 1977 Regional Plan, and has been some two years in the making.
The Plan was developed by a Task Force consisting of representatives from the
appropriate agencies of each of the four Northwest States, the Northwests electric
utilities, federalagencies, and the Direct Service lndusties.
STRUCTURE
The Plan is divided into three separate parts as follows:
l. REGIONAL CURTAILMENT PI-AN FOR ELECTRIC ENERGY (detailed version)
II. APPENDICES
III. CONDENSED VERSION. REGIONAL CURTAILMENT PLAN
FOR ELECTRIC ENERGY
TABLE OF CONTENTS
I. REGIONAL CURTAILMENT PI.AN FOR ELECTRIC ENERGY PAGE
1SECTION I.
sEcTtoN il.
sEcTtoN m.
SECTION IV.
SECTION V.
SECTION VI.
sEcTloN vll.
sEcfloN vilt.
SECTION IX.
SECTION X.
Purpose of The Regional Curtailment Plan
Overview of The Regional Curtailment Plan
Definitions
Curtailment Stages
lnitiation of Regional Load Curtailment
Ad ministration of State-lnitiated Curtail ment
Utility Liability and Financial Relief
Annual Review, Post-Curtailment Evaluation,
and Update of the Regional Curtailment Plan
Description of Appendices
Volume ll- Related Curtailment lnformation
3
5
8
11
1s
30
31
31
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II. APPENDICES
A.
B.
c.
D.
E.
F.
r.r.
The Regional Electric Energy Curtailment Analysis Model
Types of Curtailment lnformation
Curtailment Measures
Utility Curtailment Report
Contact lnformation Regarding the Utility Coordinator, State
Contacts, and Utility Contacts
State Statutes and State Agencies
Annual Updates to the Plan
lll. CONDENSED VEHSION - REGIONAL CURTAILfT,IENT PLAN FOR ELECTRIC ENERGY
REG I ONAL CU RTAI LIIJI ENT PI.AN
FOR ELECTRIC ENERGY
within the States of Washinoton. Oreqon. ldaho. and Montana
SECTION I. PURPOSE OF THE REGIONAL CURTAILMENT PI.AN
While utilities in the Pacific Northwest plan in such a way as to ensure that they have, or can
readily acquire, adequate resources to serve their loads, the potentialfor a protracted electric
energy shortage still exists. Such a shortage could result from a number of causes such as a
prolonged drought that greatly reduces hydroelectric capability, severe operational constraints
that could likewise reduce hydro capability, a moratorium on the operation of one or more coal
or nuclear plants, or the loss of a major thermal resource due to mechanical or electrical
failure. lt is also possible that a shortage could develop as a result of utilities being unable, in a
timely manner, to site and build new resources to serve a growing load - either because of
unanticipated load growth or because of unforeseen delays in bringing a resource on-line in
time to serve expected new loads.
Under most circumstances, the region's utilities will be able to handte such energy shodages
by buying and selling energy among themselves. Prices will rise, due in part to the operation
of more expensive resources and in part as a result of the increased risks to which the selling
utility is exposed. Resources will be operated at capacityto maximize energy output, and
resewes will be tapped. Depending on the severity of the protracted regional electric energy
shortage, State action may also be required.
Throughout this Plan, the tem 'State-initiated'load curtailment is used. This term refers to
State appeals requesting or mandating load curtailment by regionalconsumers. State
curtailment activities would be coordinated wtth, and supportive of, utility actions aimed at
preventing or reducing the duration and impacts of a protracted energy shodage.
This Plan identifies the process by which States would initiate and implement regiona! load
curtailment and provides detailed procedures to be followed during a protracted regional
electrical energy shortage to ensure uniform treatment of all regional consumers. State action
might also be required to assist utilities during short-term emergencies (such as shortages
resulting from extremely cold weather or the temporary loss of a major transmission line).
However, in such circumstances each State would probably act individually since the
emergency would likely be over long before the inter-State coordination required by this Plan
could occur.
Appropriateness of a Reqional Approach to State-lnitiated Curtallments
This Plan articulates the common approach to energy curtailments that has been adopted by
each of the four Pacific Northwest States: Washington, Oregon, ldaho, and Montana. These
four States are, in effect, an 'electrical region,' as together they comprise the principal
marketing area of the Bonneville Power Administration (BPA) and the seruice areas of public
and investor-owned utilities in the Pacific Northwest. Although there are connections with
utilities outside the Northwest to the north, south, and east, these connections primarily exist
for the purpose of importing, exporting, or exchanging surplus power. These non-regional
utilities are not directly affected by this Plan, although they will doubtless be asked if they can
assist in alleviating a shortage.
Most of the large power plants serving the Northwest are either owned by a consortium of
utilities lrom around the region or by the Federal govemment. Any action or event that affects
or limits the operation of any such plant will obviously have regional impacts. lt is possible, of
course, that circumstances could arise that would appear to confine a shortage to a one or two
State area. For example, unanticipated load growth in only one State could create a shortage
among that State's utilities while appearing to have no impact on utilities in the otherthree.
Nonetheless, the States recognize that such a shortage is still, in reality, a regional problem.
The nature of the interconnected regional power system is such that a problem on one system
atfects others throughout the Northwest, with no regard for State boundaries.
Furthermore, the hydro system is coordinated throughout the Northwest and resources located
in one State are not just dedicated to serving the consumers in that State. Hence, lf the hydro
system cannot make up the deficiency for whatever reason, the impact will be felt throughout
the Northwest. Utilities within the four-State area have long recognized this reality and have
historically coordinated operations among themselves for the purpose of ensuring the most
efficient operation of the combined system and assisting each other to avert regional electric
failures. The States also understand this fact; this realrty was reflected in their respective 1977-
78 load curtailment plans and forms the conceptual basis of this Plan as well.
Section 11(b) of the utilities' 1981 power sales contracts with BPA directs BPA to make
payments to utility customers during periods of State-initiated load curtailment provided they
are'metered requirements'or'actual computed requirements'customers. (!f a State govemor
issues a request for voluntary curtailment, payments are required only if BPA also publicly calls
for curtailment; if States order mandatory curtailment, BPA must make the payment inespective
of its own actions.) Such payments would affect the rates of BPAs customers throughout the
region (and, hence, consumers throughout the Northwest), not just the rates of utilities located
in the States that required cudailment. As a result, it makes sense for the four States to act
together in calling for load curtailment.
For all these reasons, it is highly appropriate for the four States to coordinate their actions and
treat any protracted energy shortage as a regional energy problem. This ensures that the
impacts of a shortage are addressed in a consistent and equitable manner throughout the
region and no single group of consumers is unduly affected.
Goals of the Plan
The principal goal of this Plan is to describe, in reasonable detail, the manner in which the four
Pacific Northwest States intend to administer regional load cudailment. ln developing the PIan,
the States have weighed the need for specificity (having a wellthought-out Plan that provides
sutficient detail as to be administratively feasible and readily implementable) against the need
for flexibility (essential for administration of the Plan during a curtailment, given that actual
circumstances may make it advisable to change at least some aspects of the Plan). This
balance of specificity and flexibility has been accomplished by vwiting the Plan to reflect the
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intent of the States in curtailment administration (explaining the types of activities that need to
be undertaken during a curtailment and providing the rationale and intent behind the
suggested actions), but leaving open the possibility of adjusting the identified procedures to
better fit the unique circumstances existing at the time of actual load curtailment.
This Plan is intended to achieve the desired level(s) of curtailment while:
treating consumers and utilities equitably,
minimizing adverse personaland social impacts (economic, physical, and
otherwise),
ensu ri n g etfici ent administrative processes,
minimizing administrative requirements, and
complying with existing State laws and regutations.
The States recognize that the Plan, by necessity, represents a compromise among the
identified goals. Where conflicts have arisen (for example, equitable treatment of consumers
may impose burdensome administrative requirements on utilities), the States have striven to
achieve the balance that is, overall, most equitable and administratively feasible.
The States realize that equity is an elusive concept and the degree of sacrifice required by one
consumer under the Plan may differ significantly from that required of another. That is true not
only lor individual consumers within a customer class, but also between types of consumers
(Residential, General Use and Major Use Consumers). Communities dependent on the fate of
a single industry wi!! likely have different service priorities during a period of load curtailment
than those with no industrial base whatsoever. After considerable discussion and debate, the
States have concluded that equitable treatment of consumers and utilities in a comprehensive
Plan covering afour-State area can best be achieved by demanding similar sacrifices from all
affected parties both in terms of the nature (voluntary vs. mandatory) and scope (percentage
reductions required) of curtailment. Nonetheless, the time may come during a curtailment
when the need for load reduction is so great as to require even greater sacrifices on the part of
those still able to make further cuts in their electric energy consumption. At that point, equity
would be defined in terms of the ability of consumers to provide load curtailment.
The Plan as a Guideline for lndivldual State Plans
This Plan serves as a guideline for the four individual States to use in developing their own
curtailment plans. Each State will afford affected utilities and ultimate consumers an
opportunity to comment on the proposed State plan before its adoption. As a result of such
public involvement as well as ditfering statutory authorities and State policies, the individua!
State plans may differ to some extent; nonetheless, they will all reflect a common goal: to
reduce electric energy consumption during a protracted electric energy shortage while
protecting critical loads and minimizing economic disruption throughout the region.
SECTION II. OVERVIEW OF THE REGIONAL CURTAILMENT PI.AN
This Plan is designed to ensure that any regional curtailment will be uniformly initiated and
equitably allocated among all consumers in the Pacific Northwest to the extent practicable.
Five stages of load curtailment are identified in this Plan, although they are not necessarily
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implemented sequentially. Once the States have evaluated the severity of the situation (the
amount and expected duration of the energy shortage) and determined that load reductions
are required, they will initiate regional load curtailment at the appropriate stage and level
(percentage reduction) in conformance with the provisions of their respective State plans.
ln the first three stages, requested or mandatory levels of curtailment are similar in nature and
scope, meaning that curtailment is either voluntary or mandatory for all consumers, and all
consumers are asked for the same percentage reductions in electric energy consumption.
Uniform curtailment is simple to understand, easy to communicate, and generally perceived as
fair as it minimizes the impact on any single consumer or consumer class by treating all
consumers the same way. The final two curtailment stages depart from the principle of
identical treatment of all consumers. Before implementing either curtailment stages 4 or 5, the
States will have concluded that the necessary load reduction cannot be achieved under an
approach that requires similar percentage cuts in consumption by all consumers. Under such
circumstances, the States will attempt to secure the necessary cudailments from those best
able to provide further load reductions. Due to the differing consumer mixes among the
region's utilities (in terms of the relative numbers of Residential, General Use, and Major Use
Consumers), the curtailment levelfor each utility's service area in either Stage 4 or 5 would
likely be unique.
Curtailment is measured on a consumer-by-consumer basis by comparing power consumption
in the current billing period to power consumption in the conesponding bitling period of the
year preceding the initiation of load curtailment underthis Plan. Requesting curtailment as a
percentage reduction in consumption is appropriate in that it is relatively easy to measure and
doesnt require on-site monitoring of behaviorfor compliance, such as would be necessitated
by a prescriptive approach that would mandate the taking of certain curtailment actions. The
percentage reduction approach does, however, have the drawback of failing to take into
account the fast that many consumers have already incorporated curtailment measures into
their lifestyle. As a result, the maximum amount of curtailment that can be reasonably
expected from such consumers may fall short of the anticipated savings from the measures
identified in Appendix C.
Achieving the desired level(s) of curtailment is a function ol a number of factors, such as
motivating all padies to 'do their part,'identifying clear curtailment goals, providing clear and
concise instructions to utilities and ultimate consumers, administering the curtailment
etficiently, and focusing administrative efforts on those consumers with the greatest curtailment
potential. The applicable curtailment stage will normally be determined by the States in
consultation with the region's utilities. ln all probability, the States willfirst initiate voluntary
curtailment, moving to mandatory curtailment only if the energy situation deteriorates or the
required amount of curtailment is not achieved through voluntary efforts.
The State agencies administering curtailment have agreed to general procedures for
announcing State-initiated curtailments and implementing their respective State plans. Despite
the fact that the Plan explicitly provides for hardship exemptions from mandatory curtailment
for both utilities and ultimate consumers, it is the intent of allfour States to elicit widespread
compliance with the curtailment orders as issued. To encourage curtaitment consistent with
State directives, the Plan includes penalties lor non-exempted consumers who lailto curtailas
required. To motivate consumers to curtail in excess of the requested amounts, utilities are
encouraged to offer incentives to those who provide more than their share of curtailment.
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This Plan describes the process by which the States will determine if curtailment is needed. lt
identifies the actions required of States and utilities to administer curtailment and articulates the
@mmon understandings as to how the curtailment message will be delivered and enforced.
The Plan also includes reference material related to curtailment: (A) a discussion of the
computer model that will be used to anallze the need for load curtailment, (B) a description of
the types of information that will be needed if curtailment is required, (C) a listing of actions
consumers could take to achieve the requested curtailment, (D) a description and sample copy
of the curtailment form that utilities will submit to the l.Xility Coordinator and their respective
States during load curtailment, (E) identification of the indMduals wlro will serve as contacts for
their respective organizations for curtailment matters, (F) a listing of State statutes addressing
cuftailment along wtth the organizations in each State that are involved, either directly or
indirectly, in curtailment matters, and (F) a summary of the changes that are made to the Plan
over time.
SECTIONIII. DEFINITIONS
The lollowing definitions apply to terms used in this Regional Curtailment Plan and in individual
State plans. lf the first letter(s) of the term are shown in parentheses, the term may appear in
either upper case or lower case throughout the Plan.
A.Base Billing Perlod. A'Base Billing Period'is one of the billing periods comprising the
Base Year. Billing Periods are established by the utility and are normally monthly or
bimonthly. 'Monthlf consumers would normally have 12 Base Billing Periods in their
Base Year. Given a 6 month curtailment, only 5 of those Base Billing Periods would be
used for measuring the amount of curtailment achieved; however, if the curtailment
were to last 17 months, all 12 Base Billing Periods would be used, 5 of them twice.
Under the Plan, utilities weather-nonnalize Base Billing Period energy consumption data
before calculating the amount of curtailment achieved in a given billing period.
B.Base Year. The 'Base Yea/ is typically the l2-month period immediately preceding
imposition of State-initiated load curtailment. lf energy use during that period is
atypical, States may select a ditferent l2month period as the Base Year. Weather-
normalized energy consumption data from the Base Year is used in computing the
amount of curtailment achieved underthis Plan.
c.Critical Load Consumer. A'Critical Load Consumer' is one that supplies essential
seruices relatlng to public health, public safety, or energy production. ln some States,
types of consumers that are deemed to be of a Critical Load nature are identified in
State statutes pertaining to load curtailrnent.
Curtallment. 'Curtailment' is load reduction, inespective of the means by which that
reduction is achieved.
Curtailment Taroet. The 'Cudailment Target' is the ma,rimum amount of energy that a
consumer may use during periods of State-initiated load curtailment and still remain in
compliance with the State cuftailment order. Curtailment Targets are figured
individually for consumers. Curtailment Targets are calculated for individual Base Billing
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Periods by reducing weather-normalized Base Billing Period consumption by the
percentage reduction in load ordered by the State. (For exampte, given a weather-
normalized Base Billing Period load of 1462 kwh and an orderfor 10% load curtailment,
the Curtailment Target would be 1316 kwh.)
Excess Power Consumption. 'Excess Power Consumption' is the load subject to
penalty underthis Plan. Penalties are not assessed if a consume/s load (either actual
load or weather-normalized load) is equal to, or less than, the Threshold Consumption
Level. Excess Power Consumption is the lower of the following two values for each
sampled load subject to penalty: (1) the difference between a consume/s actual (or
metered) consumption levelduring a billing period and the Cuilailment Target, or (2)
the ditference between the consume/s weather-normalized energy use during a billing
period and the Curtailment Target.
Extra-Reqional. The expression 'extra-regional' is a term of art that refers to any load,
resource, or entity located outside of the region as defined in section 3.(14) of P.L. 95-
501, the NW Power Act. That definition proMdes: the area consisting of the States of
Oregon, Washington, and ldalro, the poftion of the State of Montana west of the
Continental Divide, and such portions of the States of Nevada, Utah, and Wyoming as
are within the Columbia River drainage basin and any contiguous areas... which are
part of a seruice area of a rural electric cooperative served by the Administrator.' Sales
to PacifiCorp's Northem Califomia consumers are therefore extra-regional. Sales to
Montana Power Company's control area loads east of the Continental Divide are also
extra-regional, but underthis Plan they are included in Regional toad.
General Use Consumer. A'General Use Consumef is any non-residentialconsumer
who does not quality as a Major Use Consumer.
lmplementation Record. The'lmplementation Record'is the collection of significant
notes, memos, correspondence, and other material generated for each curtailment,
whether such documents are formal or informal in nature. The lmplementation Record
is both a living reference document during each curtailment period and an historical
record thereafter. The Utility Coordinator is responsible for maintaining the
lmplementation Record.
Malor Use Consumer. A'Major Use Consumef is one who has purchased over 5
average annual megawatts during the Base Year. (Any consumer using over 43,800
MWh during the Base Year would quality as a Major Use Consumer.)
Non-Reqional. The term 'non-regional' refers to any load, resource, or entity that is
located outside of the region as defined in this Plan. For purposes of this Plan, all
power sales to utilities and/or consumers located outside this four-State area shall be
considered non-regional sales, even if such sales are to entities that are located within
the bounds of the'region'as defined in section 3.(14) of P.L 9$501, the NW Power
Act. Sales to PacifiCorp's Northern Califomia consumers and sates to BPAs metered
requirements consumers outside the four-State area are non-regional even though they
are served from resources that are otheruise dedicated to serving Regional Load.
L. Plan. The'Plan'is this Regional Curtailment Plan for electric energy shodages.
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Reolon. The 'region' includes the States of Washington, Oregon, ldaho, and those
portions of Montana that are west of the Continental Divide and/or within the control
area of the Montana Power Company. Non-regional utilities and non-regional
consumers who purchase power from regional utilities are not directly affected by this
Plan since the four Pacific Northwest States lack jurisdictional authority over such
utilities and consumers.
Reoional Electrlc Eneroy Curtailment Analysls Model. The'Regional Electric Energy
Curtailment Analysis Model' (REECAM) is a computer program used by the Utility
Coordinator and other interested parties to evaluate the status of the regional electric
power system and analyze the need for region-wide curtailment. REECAM is described
in detail in Appendix A.
Reqional Load. The'Regional [oad'is the load placed by ultimate consumers within
the region on their respective utility suppliers and is the load subject to curtailment
under this Plan. Both firm and non-firm loads are to be curtailed during periods of
regional load curtailment. (However, because the States expect all regional non-firm
loads to be already otfline to the extent permitted by contract before imposition of
regional load curtailrnent and since cufiailment is to be measured relative to firm load,
the curtailable load input in BEECAM is identified as'regionalfirm load.') Sales to non-
regional retailconsumers are not included in Regional Load since Pacific Northwest
States lack jurisdictional authority over such consumers and cannot, therefore, require
them to curtailtheir purchases. Sales to utilities (whether regional or non-regional) are
excluded from Regional Load; the purchasing utility sees the sale as a resource. Any
curtailment of wholesale sales will occur at the retail level. ln REECAM, the assumption
that Regional Loads are served by a single utility makes it unnecessaryto model intra-
regional wholesale power sales. Non-regional (wholesale or retail) loads of regional
utilities are captured in the non-regional firm sales input, since they are firm
commitments that regional utilities rnust honor and to which they must dedicate
regional resources.
Statg. 'State' refers to any of the four Pacific Northwest States: Washington, Oregon,
ldaho, and Montana.
State Contact(s). 'State Contacts' refer to individuals who, in an official capacity,
represent their respective States in connection with curtailment issues. Appendix E of
this Plan identifies the organization in each State designated to implement regional
curtailment on behalf of that State as well as a primary and secondary State Contact
within that organization.
State-lnltiated. 'State-initiated' refers to actions taken by the States to implement their
individual State load curtailment plans. The State govemments'principal role during
voluntary curtaitment will be to assist the region's utilities ln their efforts to secure the
needed load reductions. Such assistance will include requests from the State
govemors lor load cudailment by consumers in their respective States. The decision to
initiate mandatory load curtailment is a State government decision made in consultation
with the atfected utilities in the region (through the Northwest Power Pool). The States
will be directing the mandatory curtailment stages, and the utilities'primary role will be
to advise and assist the States.
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S.Threshold Consumption Level. The Threshold Consumption Level'is the maximum
amount ol energy that a consumer can use during a period of mandatory load
curtailment without being subject to penalties under this Plan. The Threshold
Consumption Level is measured relative to the consumefs Cudailment Target. The
States may set different Threshold Consumption l.evels for different consumer classes
and may change such levels as they deem nec€ssary.
Utllitv Contact(s). 'Utility Contacts'referto lndividuals who, in an official capacity,
represent their respective utilities in connection with curtailment issues. Appendix E of
this Plan identifies the primary and secondary tlility Contacts appointed by each of the
respective regional utility members of the Northwest Power Pool (NWPP). These
individuals will be contacted directly by the States, the NWPP, and other utilities with
respect to curtailrnent issues. BPAs Area and District Offices will disseminate
curtailment information to all other regional utilities.
U.UtiliV Coordinator. The 'Utility Coordinatof refers to the Director of the NWPP. As
l.Xility Coordinator, the Director will be responsible lor consulting with the region's
utilities and then notifying State Contact(s) of system conditions that might wanant
implementation of the Plan. ln addition, the LJtility Coordinator will be responsible for:
(1) conducting analytical studies to assess the initial and continuing need for
curtailment, (2) maintaining a close liaison with State Contasts in reporting the status of
the power system and curtailment effects, (3) assisting utilities in cudailment matters
particularly with respect to technical issues and inter-utility coordination, (4) providing
interested parties with analytically-based information related to cuftailment, and (5)
maintaining the otficial lmplementation Record for each cuilailment period.
Utllitv Curtailment Reports.'Utility Curtailment Reports' are reports summarizing
curtailment data; such reports are to be submitted monthly by utilities to their respective
States and the tXility Coordinator. l.Jtility Curtailment Reports are further described in
Appendix D. A sample report with associated instructions is also included in the
Appendix.
W Weather-Normallzatlon. Weather-normalization'is the procedure that utilities use to
reflect the impact of weather on utility load levels. Some utilities refer to this process as
lreather-adjustment.' The purpose of weather-normalization is to determine what loads
would have been under'normal' or'average' weather conditions. Weather-normalizing
load data protects consumers from being penalized for overconsumption due to the
impact of abnormal weather conditions.
SECTION IV. CURTAILJT/IENT STAGES
Under this Plan, State curtailment directives apply to all Begional Loads. Curtailment is
requested or ordered as a percentage of historical, weather- normalized (Base Billing Period)
electric energy consumption. For example, if 15% curtailment were ordered in Stage 3,
consumers who were already complying with a Stage 2 request for 10% voluntary curtailment
would only need to curtail an additionalS%.
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The five stages of curtailment can be summarized as follows:
Staqe # Nature Curtallment % Type of Cuilailment
Stage 1 Voluntary No Specified % Uniform among allregionalconsumers
Stage 2 Voluntary 5% + Uniform among all regionalconsumers
Stage 3 Mandatory 5% - 15% Uniform among all regional consumers
Stage 4 Mandatory 15% Residential Consumers
15% + General Use Consumers
15% + Major Use Consumers
Stage 5 Mandatory % Associated Continued Consumer Curtailment
with Stage 4 plus l.Jtility Action, including
+ additional Plant Closures and possiblecurtailment Black-Outs
Although the curtailment stages are generally associated with increasing deficits, the stages
are not necessarily implemented in a sequential manner. For example, the initial State
determination of the need for curtailment could easily result in a Stage 2 curtailment order. (lt
is likely that the States would lnitially call for voluntary curtailment, although the requested !eve!
might be significantly more than 5%.) lf the situation were to ease, the States might be
prompted to rescind Stage 2 directives and replace them with a Stage 1 appeal for voluntary
curtailment. Altematively, if the situation were to deteriorate rapidly, the States could move
directly into Stage 4 cuftailment.
A. Voluntaru Curtaltment
(1) Stage 1. Stage 1 is informal in nature and is associated with the amount of
curtailment that could be elicited by media requests for prudent energy use.
Sucfi requests would be accompanled by newspaper, TV, and/or radio repofts
about problems that the region's utilities are facing. Any ongoing utility etforts
urging prudent use would be continued and possibly stepped up. States would
likely calllor Stage 1 curtailment if REECAM forecasted a need for a modest
amount of curtailment overthe anticipated shoftage period, and energy planners
thought it prudent, based on their analysis of the situation, to actively encourage
the public to pay attention to their energy consumption habits.
(2)Stage 2. Stage 2 is the second, and find, stage of voluntary curtailment. !t is
associated with curtailment of at least 5% of regional load relative to
consumption in the Base Year. The primary differences between curtailment
stages 1 and 2 are in howthe need for curtailment will be communicated to
consumers and on the amount of curtailment required. ln stage 2 (and later
stages as well), utilities will be required to provide curtailment tips to consumers.
It is anticipated that the second stage of voluntary curtailment, with its more
specific guidance for consumers, willelicit more cudailment than the broader,
more general approach of Stage 1.
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B. Mandatorv Curtallment
Stages &5 are mandatory and will be implemented only if the governors or appropriate
State authorities have signed formaldeclarations calling for mandatory curtailment of
electric loads. lt is unlikely that mandatory curtailment will ever be required given that
both the States and utilities prefervoluntary curtailment, and voluntary curtailment is
expected to produce significant energy savings. However, since it is prudent to plan for
a lrorst case'scenario, mandatory curtailment procedures have been developed to
prevent the region from moving directly lrom voluntary curtailment (that has failed to
produce the required load reductions) to rotating black-outs. Mandatory cuftailment is,
in effect, an insurance policy that is described in sufficient detail in this Plan that it is a
realistic'intermediate'option; it is leasible lor most regional utilities to implement in the
manner described, and those utilities that are unable to comply with the requirements of
the Plan may appealto their State for needed exemptions.
There are several reasons why the States might choose to impose mandatory
curtailment in lieu of continuing to solicit voluntary curtailment. lf the States believe that
regional consumers as a whole are curtailing, but making only a half-hearted etfort
despite State pleas, they might impose mandatory curtailment in order to provide an
added incentive to curtail up to the full amount of the State request. Another reason for
imposing mandatory curtailment would be to achieve a more equitable sharing of the
curtailment burden: increasing the level of voluntary curtailment further taxes those that
have already striven to comply with State requests relative to those who have made no
such effort.
(1)Stage 3. Stage 3 is the ftrst mandatory curtailment stage and is associated with
curtailment levels (i.e., percentage load reduqtions) of at least 5% and no more
than 15%. (Ihe maximum amount of curtailment that is expected to be widely
achievable in the residential sector ls expected to be 15%. Stage 3 mandatory
curtailment, which involves the same percentage load reduction by all regional
consumers, would therefore be capped at the 15% leve!. Voluntary curtailment
in excess of that amount would still be encouraged from those who could safely
provide additional curtailment.)
(2t Stage 4, ln Stage 4, uniformity ends for regional consumers as a whole, but it is
preserved wtthin consumer classes. The States will probably continue to seek
15% curtailments from the residential class, but General Use and Major Use
Consumers will be asked forfurther load reductions. ln all liketihood, Major Use
Consumers will be asked for deeper curtailments than General Use Consumers.
Because utilities have different consumer mixes, Stage 4 would mean the end of
uniform curtailment (on an overallpercentage basis) among utilities.
(3)Stage 5. Stage 5 is, in effect, curtailment of the last resort. Al! Stage 4
curtailments would be continued and additional measures undefiaken. The
States would work closely with utilities to ensure that the needed curtailment is
-10.
achieved - by whatever means necessary. Even deeper curtailments would be
encouraged or mandated, and Malor Use Consumerc might be shut down.
Even so, black-outs, potentially affecting all consumers, might be inevitable.
SECTION V. INITIATION OF BEGIONAL LOAD CURTAILJT'IENT
This section desqibe how the States determine that regional curtailment is needed (how
rnuch curtailment is required and the appropriate curtailment stage to achieve the needed load
reduction). Also described is the process by wtrich regional curtailment will be initiated and
implemented.
A. Determlnation of the Need for State-lnltlated Curtallment
The procedure for determining the need for Stateinitiated curtailment will be as follows:
(1) State Notiflcation of Potential Energy Shortages by the Utillty Coordinator.
As Director of the NIWPP, the l.Jtility Coordinator is responsible for working with
the region's utilities and keeping abreast of power system conditions. Whenever
it appears that a protracted energy shodage could be developing, the Utility
Coordinator shall so notify l.Xility Contacts and State Contacts.
(21 Updatlng of Load/Reaource Studlee. As energy conditions dictate, the Utility
Coordinator shall examine the results of REECAM and update other ongoing
studies of regional load and resource conditions to reflect the latest electric
system conditions. The purpose of these efforts is to provide an analytical basis
for determining whether or not there is a need for State-initiated regional load
curtailment to alleviate the energy deficiency.
Evaluation of the Need for State-lnltiated Curtailment. Following preparation
of the numerical analysis of regional load/resource conditions, the Utility
Coordinator will convene a meeting of State Contacts, l.Xility Contaqts, and other
interested utilities forthe purpose of determining whetherthe numericalanalysis
demonstrates a signfficant forecasted regional deficit. Based on the information
presented at the meeting, the lour State Contacts will reach consensus on
whether regional load curtailment is required.
(4)Determlnatlon of the Approprlate Stage and Level of Curtallment. Although
the States will be aware of an energy shortage as it develops, they will become
actively involved in managing the shortage only after reaching the conclusion
that State.initiated load curtailment is needed to manage the regional energy
deficiency. The determination as to which curtailment stageflevel combination is
appropriate for the particular circumstances existing at the time will normally be
made by States in consultation with the lJtility Coordinator and the region's
utilities.
The following procedure could be used to establish the applicable curtailment
stage and associated curtailment level:
3)
-1 1-
(a) Shortaoe Perlod. Establish the time period over which the shortage is
anticipated to occur.
(b) Amount of the Shortaqe. Bracket the amount of the shortage, by
month, quantifying the shortage based on cunent expectations of the
best and worst possible outcomes given existing system conditions (as
described by the l.Xility Coordinator) and a variety of potential events
affecting system loads and resources.
(c) Curtailment [.evel. Establish the curtailment level (i.e., percentage load
reduction) required to alleviate the deficiency in each month of the
shortage period. ln so doing, take into account the full spectrum of
possible deficits and their associated probabilities of occunence.
(d) Lead Time. Estimate the amount of lead time before the onset of the
physical shortage. (lt may be that utilities can meet all of their load at the
present time but anticipate being unable to do so in the future;
altematively, the deficit may already be affecting the utilities abilityto
provide reliable electrical service.)
(e) Appllcable Curtallment Staoe and Percentage [.evel. Seleqt the
applicable curtailment stage and level based on the above data while
keeping in mind the following considerations:
G)Curtaltment Adequacy. Ensure that the proposed level ol
curtailment is adequate to achieve the required results, giving
reasonable weight to a worst-case scenario. Bear in mind that
curtailments are measured relative to historical, weather-
normalized energy consumption (Base Billing Period) data, not
cunent load levels. Adjustrnents of Base Billing Period data and
loads exempted from Plan requirements will reduce the amount of
curtailment achieved relative to the requested percentage load
reduction.
(A Contlnuity. Avoid changing stages and levels any more
frequently than absolutely necessary. Changing stages and
levels is costly and dfficult, particularly when there is a movement
from voluntary to mandatory curtailment.
e)Preference for Voluntary Curtallment. Avoid mandatory
curtailment if practicable since mandatory curtailment will be both
administratively and politically costly relative to voluntary
curtailment.
($ low l.evel Curtallment. Specity a longer period of low level
curtailment in lieu of a shorter period of more extreme curtailment.
This preference reflects the following:
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(g) Coneumer Adlustment and lmpact on Consumers. lt
takes time for consumers to adjust consumption levels.
The more extreme the adjustment, the more difficult the
adjustment becomes and the greater the hardship on
consumers.
&) lmpact on Utlllties. Lower levels of curtailment have a
smaller long-term impact on utilities. (Ihe revenue impact
is spread over time and the lasting impacts on
consumption may be lower.)
G)Degree of Curtailment and Ditficulty of Changlng
Course. The higher the curtailment stage and level and
the more drastic the actions required of consumers,lhe
more difficult it is to change course - both administratively
and politically. (ln other words, it is relatively easy to allow
requests for low key cuftailment appeals to fade away
without much todo. The public is also more likely to
understand the need for mandatory curtailment if it has
been preceded by a period of ongoing appeals for
voluntary curtailment. ln contrast, announcing the need
for mandatory curtailment and then reversing the order
soon thereafter as a result of dramatically changed
circumstances would likely lead to consumer cynicism
qulte apart from the administrative difficulties involved.)
Worst€ase Plannlng. lf possible, select a curtailment levelthat
would enable the States to avoid calling for Stage 4 or Stage 5
curtailment even if worst-case conditions were to materialize.
Fatse Starts. Avoid triggering an unnecessary callfor
curtailment. (Ihe goal is to avoid implementing the Plan for a
short-term problem that might be caused by'noise'in load
and/or resource variation and to eliminate false starts such as
could occur when a problem is real but unexpectedly dissipates.)
B. Process for lnitlating Reoional toad Curtailment
(1) Brlefing Package. Once the State Contacts have agreed on the need for, and
appropriate levelof, regional load cuftailment, the l..ttility Coordinator, working
together with the State Contacts, Utility Contacts and other lnterested utilities,
will prepare a document explaining:
(a) the reasons behind the shodage;(b) the level of curtailment required to bring the system back into balance;
and(c) the expected duration of the problem.
(s)
G)
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The Utility Coordinator is responsible for preparing the material to ensure that
State managers in all four States are provided with exactly the same factual
information about the energy situation. Any background material and numerical
analysis usefulfor briefing Energy ffice, tXility Commission, and other State
govemment personnel will also be included. The Utility Coordinator will
distribute this materialto each State Contact and all regional utilities.
State Management Briefings. Once the briefing materials have been
disseminated, State Contacts will brief their management on the need for
regional curtailment.
Coordination Among State Contacts. Following the briefing of State
management, the State Contacts willagain coordinate with each otherto ensure
that the consensus developed in the evaluation process remains and that State
management in each State is comfortable with the joint recommendation. To
the extent changes in the original recommendation are indicated as a result of
intra-State consultations, the State Contacts willwork togetherto reach a new
consensus.
(4) Establishing the lmplementation Record. Once the State Contacts have
affirmed the need for a given level of regional curtailment, they will begin
developin g situation-specific implementation procedures. Throu g hout the
curtailment, significant agreements will be put in writing and included as part of
the I mplementation Record lor the curtailment.
(5)Govemors' Briefings. The State Contacts will brief their respective State
govemors on the need for region-wide load curtailment.
C. Process for lmplementlno State-lnltiated Curtallment
(1) Declaration of Curtailment. Once any necessary inter-State coordination has
occured (procedures have been established and decisions made) and upon
receipt of any applicable curtailment orders (if mandatory curtailment has been
declared), the State Contacts will formally notfy the utility Coordinator and all
utilities operating wtthin their respective borders that regional electric load
curtailment is in etfect.
lf any stage associated with a specific level of curtailment is declared (Stages 2-
5), the States will publicly announce the need for curtailment and provide all
utilities operating within their respective borders with written instructions
regarding utility obligations during periods of State-initiated load curtailment.
'Lost revenue' payments to utilities under section 11(b) of the utility power sales
contract with BPA are triggered by BPA and one or more State govemors
requesting voluntary cuftailment; State action alone will trigger the payments if
mandatory curtailment has been declared. (Note: while declaration of a
shortage by the States may trigger curtailment payments by BPA, such
declaration would not necessarily cause BPA to declare a'planning
insutficiency' such as described in section 7 of the utility power sales contract.)
(2)
(3)
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(2)
(3)
SECTION VI. ADMINISTRATION OF STATE.INITIATED CURTAILMENT
A. Utility Activities
(1) Overview
(a) Abllitv of Utilltles to Complv with Plan Requlrements
Public lnformatlon. ln orderto effect StateJnitiated curtailment, curtailment
information must be made available to the general public, the press, and other
interested parties. The types of materials that need to be prepared and the
parties responsible lor their preparation are identified in Appendix B, Types of
Curtailment I nformation.'
Utillty lmplementatlon of State-lnltlated Curtallment. When notified by their
respective States that their State plan has been activated, utilities shall
immediately initiate curtailment on their own systems in conformance with their
State plan and applicable utility-specific curtailment plans. (Not all utilities have
curtailment plans and, of the existing plans, some are only designed to address
short-term emergencies, not protracted energy shortages.)
The administrative requirements specified in this section have been
developed primadly with the capabilities of mid-size to large utilities in
mind. The States recognize that some utilities may be unable to comply
with all of these provisions due to a lack of administrative personnel, the
inability to modify their computerized billing programs to apply the
specified rate penalties, the lack of a computerized billing system
altogether, etc. The States expect utilities to conform to the
requirements of their respective State plans to the extent possible.
However, as needed, utilitles may petition their respective States for
exemption from speciftc requirements of their State plan. (See section
vr.A(7xd).)
(b) Staqe-by€taqe UtllityAdmlnlstratlve Oblioatlons
Upon notice that their respective States have called for regional load
curtailment, the region's utilities shall immediately begin complying with
the directives of their State plan. All requirements for lower level Stages
continue to apply to higher level stages. Throughout the curtailment
period, utilities are urged to provide consumers with as much useful
information as they reasonably can. The requirements specified below
represent the minimum actions the utility must take to remain in
compliance with this Plan.
(1) Stage 1. ln Stage 1, utilities are required to begin (or continue if
they have already begun) providing curtailment information to
their consumers. Both the nature of the information and the
means by which they convey it (media communications, bill
stuffers, etc.) are left to the utility. Utilities shall also assist States,
as appropriate, in briefing the media about the shortage.
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@ Stage 2. ln Stage 2, utilities must:
(e) notify their consumers of the percentage level of State-
initiated voluntary curtailment;
O provide curtailment tips to consumers;
O answer @nsumer questions about cuftailment;(9[) provide curtailment reports to the States and the Utility
Coordinator;and(e) provide more detailed information to the mediathan made
available in Stage 1.
(9) Stage 3. ln Stage 3, utilities must:
@) notrfy their consumers of the percentage level of State-
ordered mandatory curtailment;(!) calculate weather-normalized Base Billing Period data and
Cufiailment Targets for all consumers who are subject to
audit;
O provide Curtailment Target information to all consumers
who request such data for their own accounts. At a
minimum, utilities shall provide Curtailment Targets for the
most recently completed, the cunent, and lorthcoming
billing periods.(9[) provide audited consumers wtth information about how to
apply for exemption and adjustment of Base Year data;
(utilities may elect to provide this information only to those
audited consumers subject to penalties underthis Plan);(g) process requests for exemption and Base Year data
adjustments from consumens selected for audit and who
would otherwise be subject to penalties; and
fi) implement the sanctions aspect of the Plan (see
section Vl.A.5, below).
G)Stage 4. ln Stage 4, utilities must notify their consumers of any
applicable changes in State-initiated mandatory cu rtai I ment.
O Stage 5. ln Stage 5, utilities must collaborate with the States to
develop and implement the most effective methods for securing
the required load curtailment.
(2) Suggested Curtailment Actions
Utilities shall disseminate information to consumers regarding actions they can
take to reduce their electric energy consumption. The States and utilities will
work together to develop this material. The recommendations will be based on
the actions described in Appendix C, 'Curtailment Measures.' Utilities will be
responsible lor tailoring this curtailment inlormation to their seruice areas,
adding utility-specific information (such as whom to callwith curtailment
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questions), printing the material ln an appropriate form (brochures, bill stuffers,
etc.) and disseminating it to thelr consumers.
The curtailment tips that the utilities provide to their consumers should enable
most consumers to meet their indMdual Curtailment Target. The measures
should be business-speciftc for Malor Use Consumers and, to the extent
possible, for large General Use Consumers. The purpose of identifying specific
measures and explaining their respective impacts on energy consumption is to
familiarize consumers with options lor reducing consumption, while leaving them
free to curtail in the manner that is most acceptable to them.
(3) Base Year Data and Curtallment Targets
(a) ldentification of the Base Year
Each time the Plan is activated, the States will identify the applicable
Base Year. Once established, the Base Yearfor a shortage will remain
unchanged, inespective of the length of the curtailment period.
(1) Base Year. Normally, the Base Year is the l2-month period
immediately preceding initiation of load curtailment underthis
Plan. For purposes of application of the Base Year concept to
load curtailment underthis Plan, the Base Year is subdivided into
Base Billing Periods; a'monthlf consumer will likely have
12 Base Billing Periods; a'bi-monthlf consumer,6 Base Billing
Periods, and a'seasonal' consumer will probably have 2 Base
Billing Periods. Base Year and Base Billing Period data shall be
weather-normalized using the util itt's standard procedures.
(Utilities may choose to weather-normalize onlythose loads that
are highly weatherdependent.) l.Jtilities may apply to the States
for hardship exemption from the weather-normalization
requirement.
(A Alternatlve Base Year. The States may choose an altemative
Base Year if they decide that the data for the 12+nonth period
immediately preceding load curtailment is atypical and its use
would result in an inequitable allocation ol curtailment among the
region's consumers. Potential causes of atypical data might
include, among others, curtailment being in effect during some
months of the Base Year or a severe economic depression during
that period.
(b) Adiustment of Base Year and/or Base Billlng Perlod Data
Although the Plan calls for curtailment each billing period relative to the
consume/s weather-normalized energy consumption in the Base Billing
Period, there will be cases in which such curtailment could cause
extreme hardship due to significant changes in the consume/s
circumstances over the past year.
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During mandatory curtailment, any consumer selected for audit may
appeal to its utility lor adJustment of applicable Base Year or Base Billing
Period data. As appropriate, the utility might adjust all Base Year data or
only data for certain Base Billing Periods.
Any consumer that has requested an adjustment and is not satisfied with
its utilitt's determination relative to its request may appeal to the State for
reconsideration.
(c) Estimatlno Base Billlno Perlod Data for Consumers for Whom No
Base Billlng Perlod Data Exlsts
Base Billing Period data must be obtained or developed for any
consumer who is audited under this Plan. Ljtilities must estimate the
Base Billing Period datafor any audited @nsumerlor whom actual data
either doesn't exist or is found to be atypical or lnaccurate. For most
consumers there will be at least some actual Base Year data, although if
the consumer is new, has moved wtthin the year, orthere have been
administrative changes in the utility (such as changing meter reading
dates), there may not be afullyea/s worth of such data.
l.Jtilities shall estimate Base Billing Period data for all MaJor Use
Consumers for whom no actual billing data exists. tJtilities who elect to
include residential and GeneralUse Consumers without actual Base
Billing Period data in the pool of consumers subject to audit must also
estimate Base Billing Period data for any such consumer selected lor
audit.
(d) Curtallment Taroets
At a minimum, the utility must determine the Curtailment Target for each
consumer audited for compliance with the mandatory curtailment order.
lJtilities must also generate both retrospective and prospective
Curtailment Target data for all consumers who have requested such
information lor their own accounts.
(e) Communlcatlno Curtailment Taruet lnformation to Consumers
During mandatory curtailment, utilities are required to provide
retrospective, cunent billing period, and forthcoming billing period
Curtailment Target information to any consumer who so requests.
Utifities are also required to provide retrospective Curtailment Target
information to any audited consumer who will be issued a waming or
penalty. This information provides the consumer with direct feed-back
demonstrating the numerical basis for the utility action. At their option,
utilities may provide Curtailment Target information to other consumers
or consumer classes as well.
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(4)Auditing Consumers for Compliance wlth State Orders for Mandatory Load
Curtailment
Underthe Plan, utilities are required to audit consumers for compliance with the
orderfor mandatory load curtailment as described herein. Consumers found to
be in violation of such orders will be subject to penalties.
(a) Number of Audite - Samole Slze
Each month, a utility must audit a number of consumers equalto the
minimum sample size plus any consumers penalized in the previous
billing period. The minimum sample size is one percent ol Residential
Users, five percent of General Use Consumers, and 100% of Major Use
Consumerc. The number of consumers forthis calculation is to be
based on the total number of consumers in each class. The number of
consumers exempted or excluded from audit (see section Vl.A(4Xb),
below) will not affect the sample size. lf the States determine that
compliance with the mandatory curtailment order is low, they may
increase the required sample sizes during the curtailment period.
Auditing consumers in all sectors treats all consumers equitably and
likely results in additionalcurtailment. By allowing utilities to random
sample their smaller users for compliance, the States are minimizing the
administrative burden of enforcement. Requiring 100% auditing of Major
Use Consumers will give the greatest retum on the enforcement dollar.
tJtilities with the ability to audit more consumers than required by the
Plan are encouraged to do so.
(b) Samplino Procees
Reeidentlal and General Use Consumers. Unless a utility is
auditing 100% of its eligible Residential Users and General Use
Consumers, allsuch consumers selected for audit shall be
chosen on a random sample basis.
The following consumers are not subject to audit:
(g) consumers granted an exemption under this Plan;(b) consumens with an estimated power bill in the cunent
billing period; and
O consumers with estimated Base Billing Period data,
assuming the utility elects to exclude such consumers;
however, if the States have identified a compliance
problem arising from this'exclusion' provision during the
course of a curtailment, they may direct atfected utilities to
include consumers with estimated Base Billing Period data
in the pool of consumers subject to audit.
Exclusions may be handled either by initially removing
excluded consumers from the pool or by including such
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o)
consumers in the pooland continuing to draw samples
until enough'auditable consumers' have been identifi ed.
New samples shall be drawn each month. Any Residential
or General Use Consumer penalized underthis Plan shall
continue to be audited until its energy use falls below the
Threhold Consumption Level. Once such consume/s
energy use falls below that level, s/he will be audited again
only if selected through the utilitt's standard sampling
process. (Such selection for re-audit would normally be
as a result of random sampling, but it could be automatic
if the utility audits all consumers each billing period.)
@ Malor Use Consum€rs. All Major Use Consumerc shall be
zudited each month, including those with estimated Base Billing
Period data. Utilities are expected to work with any Major Use
Consumer who has estimated Base Billing Period data to ensure
that the estimated data is reasonable, since penalties may be
assessed if the consume/s use exceeds its Curtailment Target
and the amount of energy potentially subject to penalty is so
great.
(5) Penalties for Non-Compllance
(a) Nature of Penaltles
The Plan identifies penalties for non-exempted consumens who failto
comply with State orders for mandatory load curtailment. Penalties may
vary from State to State due to differing statutory constraints, but the
penalties underthis Plan are structured as follows:
Violation t PenalW
First Bimonthly Molation
Second Bimonthly Molation
Third Bimonthly Molation
Fourth Bimonthly Violation
Fifth Bimonthly Molation
Sixth and All Subsequent
Molations
100 per kWh of excess use
20qper kWh of excess use
400 per kWh of excess use
1 Day Disconnection +
400 per kWh of excess use
2Day Disconnection +
400 per kWh of excess use
Penalties are determined by
the State. Civil penalties or other
conective actions would be possibilities.
*The penalty lor violators who are billed every two months will
escalate on every pow€r bill in which they are subject to penalty,
Consumers billed on a monthly basis will be assessed the same
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penalty on two successive occasions before incuning the next
higherlevel penalty. This procedure ensures equitabte treatment of
all regional @nsumers in the application of penalties inespective of
their utility's billing prac{ices. During any period of curtailment,
assessed penalties remain 'on the record'for the purposes of
administration of subsequent penalties, even if there has been an
intervening period ol'compliance.' However, once all curtailment
orders have been lifted and normal utility operations restored,
penalty records are effectively purged, so that consumers would
start with a'clean slate'if mandatory curtailment were imposed
again at a later date.
Utilities are expected to adhere to their standard disconnect criteria and
procedures whenever disconnecting consumers in accordance with this
Plan. Health, safety, and welfare considerations are to be taken into
account, and consumers must pay normal disconnect and reconnect
charges. Consumers wlrose use exceeds the Cuftailment Target during
a period in which they have also been disconnected are subject to
financial penalties as well.
(b) Calculatlon of Financlal Penalties
Financial penalties will be calculated by multipllng the consume/s
Excess Power Consumption each billing period as determined in section
Vl.A(sXbXa, below, bythe appropriate penalty level identified in section
V!.A.(s)(a), above. The manner in which Excess Power Consumption is
calculated under this Plan is designed to achieve two goals: (i) avoid
penalizing @nsumers for relatively lnsignificant infractions by penalizing
onlythose whose use exceeds the Threshold Consumption Level, and
(ii) make the determination of the penalty to be imposed on weather-
sensitive consumers appear reasonable to affected consumers, thereby
significantly reducing (if not eliminating) disputes wtth consumers
unfamiliar with the impact that weather has on loads.
(1) Threshold Consumptlon Level
The Threshold Consumption Level is in essence a'dead band'or
margin of tolerance above the Curtailment Target. Consumers
using more energythan their Curtailment Target but less than the
Threshold Consumption Levelwill be issued wamings, but not
othenruise penalized for their excess consumption relative to their
Curtailment Target. ln effect, the Plan is designed to be
administered much like the speed limit is usually enforced: tickets
are given only if the violation is 'significant;' it is seldom if ever
that a vehicle is stopped for going 56 mph in a 55 mph zone.
This approach, embodied in the Plan in the form of the Threshold
Consumption Level, is expected to reduce the number of
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complaints about mandatory curtailment; lewer consumers will be
subject to penalty, and those @nsumers that are in fact penalized
will have significantly overconsumed relative to their Curtailment
Target. Since fewer @nsumers will be penalized, it is likelythat
there will be fewer requested adjustments to Base Billing Period
data and/or requested exemptions from Plan requirements, thus
reducing the administrative burden of curtailment enforcement on
both the States and utilities.
The Threshold Consumption Level assigned to each @nsumer
class is identified in the table below. lf the required load
reductions are not occuning during a curtailment period, the
States may ctange the percentage relationship of the Threshold
Consumption Level to the Curtailment Target so as to effect better
compliance with the cudailment order.
Type of
Consumer
Threshold
Consumotlon Leve!
Residential Consumers 10% above Curtailment Target
General Use Consumers 10% above Curtailment Target
Major Use Consumers 2% above Curtailment Target
e) Excess Power Consumptlon Calculatlon
Since it may be difficult to explain weather- normalization to the
general public, the consume/s weather-normalized load is used
for determining Excess Power Consumption only in those cases
where its use would benefit the consumer. That would be the
case when the weather was colder than 'average' in the winter or
hotter than 'average' in the summer.
The purpose of weather-normalizing ls to account for the real and
reasonable differences in energy consumption that will naturally
occur due to the vagaries of the weather. However, if weather-
normalizing loads has the effect of increasing loads relative to
actuals (as it does if the weather is unseasonably mild), weather-
normalizing would probably create a public relations problem for
utilities. They would have to explain to mystified consumers why
they are being penalized on energy that they 'did not take.'
lmposing a penalty in such cases could well alienate consumers
(including those making a good faith effort to comply with the
curtailment order) at the very time that public cooperation in
achieving curtailment is most needed. Furthermore, the mild
weather will, in itself, have had the impact of reducing the need
for curtailment.
Penalties are not assessed if a consume/s load (either actual
load or weather-normalized !oad) is equalto, or less than, the
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Threshold Consumption tevel. Excess Power Consumption ls
the lower of the following two values for each sampled load
subject to penalty:
G) (Actual Load) minus (Curtailment Target) or
(b) (Weather-Normalized Load) minus (Gurtailment Target)
To implement this concept, some utilities mlght prefer to
weather-normalize all sampled loads, compare the
weather- normalized results to thE'actuals'on a
@nsumer-by-consumer basis to ldentify the lower of the
two loads, determine if this load exceeds the Threshold
Consumption Level, and, if so, calculate the consume/s
Excess Power Consumption. CIher utilities may choose
first to identify those consumers who would be subject to
penalty based on actual loads and weather-normalize only
those identified loads to determine (1) if the consumer
would still be subject to penalty if weather-normalized
loads were used lnstead of actuals and (2) if so, the
amount of suclr consume/s Excess Power Consumption.
(c) Assessment of Penaltles
(1) Penaltles vs Wamlnos
Consumers will be assessed penalties only if they have Excess
Power Consumption and if they are to be penalized based on the
utilitt's penalty assessment procedures described below. Any
sampled consumer who is not penalized and whose use exceeds
the Curtailment Target will receive a waming.
@ Penaltv Assesement Proceduree
LJtilities sampling at the mandated minimum percentages for each
sector as specified in this Plan [1%-5%-100%] (or as othenruise
specified by the States and reflected in the lmplementation
Record) shall assess penalties on allconsumers with Excess
Power Consumption.
Utilities sampling a higher percentage of consumers than required
under the Plan may choose among the following penalty
assessment options:
Assess penalties on all sampled consumers with Excess
Power Consumption; (due to the 100% sampling
requirement, this methodology must be used for Major
Use Consumers even if the utility chooses option (b),
below, for its other consumer classes); or
e)
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(b)Develop a ratio of the minimum percentage sample size to
the actual percentage sampled for the Residential and/or
General Use Consumer classes. Multiply the resulting
percentages by the total number of violators ln each
respective consumer class to determine the rninimum
number of penalties that must be assessed in each sector.
(l-his methodology allows utilities to determine the
approximate number of violators that would have been
identified ln a sample of minimum size.) Calculate the
percentage violation for each individual consumer that has
been sampled (Excess Power Consumption divided by
Curtailment Target) and apply penalties to the \rorst
offenders'in the overallsample based on their percentage
'Excess Power Consumption.' lf there are clear groupings
of consumers in terms of percentage violation, utilities
may choose to penalize all consumers with violations of
approximately the same mag nitude, rath er than penalizing
only the exact number of consumers that must be
penalized based on the ratio of sampling percentages. ln
addition to penalizing the llrorst offenders,'utilities shall
also penalize all consumers who were penalized in the
previous billing period and who stillhave Excess Power
Consumption.
(g) Treatment of DSls
Penalties applicable to BPAs direct-seMce industrial customers
will be assessed by the States based on billing data provided by
BPA.
(d) Billlno Consumers for Penaltles
Utilities may describe the penatty on the power bill as'State-mandated'
and shall include any State-provided materialdescribing the penafty
aspect of the Plan as a bill str,ffer in the bills of penalized consumers.
The States willconsider printing this materialon State letterhead so as to
reinforce the publids understanding that penalties are due to a violation
of State mandate. tJtilities shall note that failure to pay penalties will
result in service disconnection in accordance with standard disconnect
criteria and procedures.
(e) Treatment of Penalties Pendlno Adiustment/Exemptlon
Determinations
Consumers who have applied for adjustment of Base Billing Period data
and/or exemption from mandatory curtailment may request a stay of
enforcement of the penatty aspect of the Plan pending a final decision
regarding its request. Any consumer who has been granted such a stay
-24-
shall be subject to retroactive penalties as applicable if the request ls
ultimately denied.
0 Use of Funde Collected under the Penalty Provislone of the Plan
Funds collected under State-ordered penalty provisions of thls Plan shall
be set aside in a separate account. The ultimate disposition of these
funds will be determined bythe appropriate State commission in the
case of investor-owned utilities and by the goveming bodies of publicly-
owned utilities.
(6) lncentives
Whenever curtailment is ln efiect, individual utilities are encouraged to
implement creatlve lncentive programs (such as incentive payments or
curtailment contests) to motivate consumeni to provide additionalload
reductions relative to their Curtailment Targets.
(7) Exemptions
(a) ConsumerAppllcationforExemptlon
Utilities are responsible for informing their consumers howto apply for
exemption from Stateordered mandatory load curtailment. Utilities may
elect to procecs exemptions only for audited consumerc who are
penalized.
Consumers seeking an exemption from any part of their State plan shall
apply first to their utility and then, if dissatisfied with that outcome, to
their respective State. The State will not consider any consume/s appeal
unless it has first been processed bythe consume/s utility.
(b) Grantino Consumer Requests for Exemptlon from Mandatory
Curtailment
The following guidelines provide a basis for ensuring consistent
exemption decisions throughout the region. At the time the States
actually initiate curtailment, they will develop more detailed guidelines
regarding exemptions and providethem to all regional utilities.
No consumer will be granted an automatic exemption from mandatory
State-ordered load curtailment. Exempted consumers should also be
told that such status may not protect them from black-outs in Stage 5.
(1) Critlcal Load Consumerg
Critical Load Consumers may be exempted once they have
demonstrated to their utility that they have eliminated all non-
-25-
essential energy use and are using any reliable, cost-effective,
available back-up energy resources to serye their load. Critical
Load Consumers are those that supply essential seruices that
provide for public health, public safety, or energy production.
The following is a non-inclusive list of typical Crttical toad
Consumers:
(g) Hospitals, nursing homes, and other health facilities;(D) Police and fire stations;
O Emergency seMces including essential communications;(g!) Sewage treatment and pollution control facilities;(e) Municipal and public watertreatment and pumping
facilities;
0 Public mass transit including airpofts, bus terminals, train
stations;and(g) Energy Supply and Storage Facilities such as:. Refineries;. Oiland gas pipelines;. Coal handling facilities;. Wood waste processing and handling facilities
directly associated wtth energy production; and. Power generating facilities.
@ Other Consumers
Exemptions for consumers not qualifying as Critical Load
Consumers underthis Plan will be evaluated based on whether
curtrailment would result in unreasonable exposure to health or
safety hazards, seriously impair the welfare of the affected
consumer, cause o<treme economic hardship relative to the
amount of energy saved, or produce counterproductive results.
(c) Utility Record-Keeplnq Relatlve to Consumer E (emptione
Utilities will need to maintain a list of all consumers applying for
exemption, noting the account, the nature of the requested exemption
(Base Year adjustment or exemption from the mandatory curtailment
order), the rationale provided by the consumer, and the action taken by
the utility wtth respect to the request. This information is to be made
available to States upon request. States will need such data to review
the appropriateness of utility determinations regarding consumer
requests for adjustment of Base Year data or exemption from Plan
requirements.
Utilities shall report summaries of their exemption determinations to their
respective States on a monthly basis.
-26-
(8)
(d) Utllltv Exemptlon from State Plan Requlrements
l.Jtilities may appealto their respective States, requesting an exemption
from any aspect of their State plan. Their petitlon for exemption should
identify the specific requirements from which they wish to be exempted,
the reason(s) behind their request, and altemative actions that they can
reasonablytake in lieu of complying wtth such requirements.
Measurement of the Amount of Curtallment Achleved and Determlnatlon of
Compliance
(a) Relatlonshlp of Consumer Curtallment to System Curtallment
Although consumers within a given utility's service area may curtail by
the amount requested by the State, the utilitt's system load may not
reflect the same percentage load reduction. l.Jtility loads will be
influenced by such factors as: the amount of power that the utility sells to
non-regional consumers (and is not subject to curtailment under this
Plan), intra-regional power sales to other utilities, load growth not
reflected in the utllitfs Base Year totals, line losses, Base Year
adjustments, exemptions, and weather-normalization.
(b) Utlllty Role ln Curtallment Measurement
To determine the amount of energy saved from State-initiated
curtailment, the States will rely on utilities to make the necessary savings
calculations.
(c) Utillty Curtailment Report
At alltimes during Stateinitiated regional load curtailment, utilities shall
provide their respective States and the LJtility Coordinator with
consumption and savings data on a monthly basis in the form specified
in Appendix D. By adopting a @mmon curtailment savings reporting
form for use by utilities in allfour States, the States are ensuring that
utilities are prepared for curtailment, curtailment data is consistent
among utilities, curtailment administration is facilitated, and a common
data base of curtailment lnlormation is established.
Although the form must be submitted monthly, the States will not require
utilities to modify their existing billing procedures; bimonthly or seasonal
accounts, for example, need only be noted as such; curtailment
information for such accounts need not be gathered or reported on a
monthly basis.
The lorm has been designed so as to include any curtaitment information
that would be required for curtailment administration. To the extent that
-27-
circumstances at the time of aqtual load curtailment dictate the need for
additional data or more frequent data submittals, the States shall so
inform the utilities and the urtilities shall use best efforts to comply with
the State request.
(9) Special Arrangements
(a) Use of Consumer€ryuned Generatlon FacllltleeThe States'mandatory
curtailment order applies onlyto electric energy purchased from a utility:
all consumers are required to reduce their electric energy purchases
from their utility by the required percentage. However, consistent with
their respective utility's needs for safety and system protection,
cpnsumers having their own generation lacilities or access to electricity
from non-utility power sour@s may use energyfrom those other sources
to supplement thelr curtailed power purchase from their electric utility.
Hence, the total energy consumption (electric or othenruise) of such
consumers may not in fact be reduced from pre-cudailment levels.
(b) Curtallment Schedullng, During periods of mandatory curtailment, a
consumer is obligated to provide the requisite amount of curtailment
within each billing period. Within that period, and subject to equipment
limitations and utility rules on load ffuctuations, consumers are free to
schedule their curtailment so as to minimize the economic cost,
hardship, or inconvenience they experience as a result of the mandatory
curtailment requirement.
Case$v4ase ArranoementsUtilities may choose to work creatively
with individual consumers to secure additional curtailments as
appropriate.
B. State Activities
(1) Providing Curtailment lnformatlon to Utilities
States shall provide utilities wtth information regarding curtailment administration
and work with utilities to develop curtailment tips for consumers. (See
Appendix B, Types of Curtailment lnformation'and Appendix C,'Curtailment
Measures.')
(2)Processlng Utillty Requests for Exemptlon and Second Level Consumer
Appeals for Adjustments and/or Exemptlons
The States shall process all utility requests for exemption from Plan
requirements. Exemptions will be granted to those making a convincing case
for their request.
The States shall also process those consumer requests for either exemption or
adjustment of Base Year data where the consumer is appealing its utility's
(c)
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(3)
determination. Throughout the appeals process, the States will periodically
inform the appealing consumers and their respective utilities of the status of the
appeals.
Periodic Reassessment of Admlnlstratlve Declslons and Malntenance of the
lmplementation Record
Together, the States will reviewthe appropriateness and continued applicability
of implementation decisions on a monthly basis, or as othenruise indicated.
Significant decisions shall be recorded ln the lmplementation Record. The
lmplementation Record will not be a formal document; rather it will simply be a
record of decisions and agreements made by the States relative to the present
shortage. The lmplementation Record will be a living documentthat will be
supptemented bythe States as requlred during the shortage period. Following
the curtailment it can be used as a reference document, providing an historical
record of the actions taken and the results thereof.
The types of matters that will be addressed in the periodic reviews and which
may be reflected ln materials that udll become part of the lmplementation Record
include:
(a) Achlevements and Oblectlves. Analysis of the amount of cufiailment
actually achieved based on the data provided in the Utility Curtailment
Reports and a review of the most recent REECAM results;
(b) Curtallment Staoe and Level. ldentification of the applicable
curtailment stage and level; also, any identified procedures for changing
the applicable curtailment stage and/or level;
(c)Public lnformatlon. The generalagreement among the States as to
how to disseminate the curtailment message: i.e., the tenor of the
message, the date of the initial announcement, any specifics as to the
mediathat may be used, etc.;
(d) Base Year Consumptlon. The Base Yearto be used for measuring
curtailment impacts;
(e) Procedural Matters.
(]) Development of additional administrative procedures as required;
@ Assessment of the need, il *y, for making changes to the Plan to
secure increased compliance with the curtailment direstives; such
changes might include, for example, changes in the Threshold
Consumption Level and/or the percentages of consumers subject
to audit;(g) Discussion of implementation problems and proposed solutions
thereto; and(!) Evaluation of the appropriateness of the materials being made
available to utilities and provided by utilities to the States, and a
-29-
determination as to whether changes are required (whetherthat
means changes to existing materials or development of new
materials);
Curtailment Records. The specific requirements on utilities and States
regarding curtailment records (wlrat needs to be recorded, howthat
inlormation will be stored, who can access it...); Considerations might
include consistency, adequacy, a@uracy, usefulness, and format of data
as well as the methodology used to determine curtailment impacts;
States should also determine whether changes need to be made to the
reporting requirements to ensure fullvalue from the reports; and
(g) Return to Normal Operatlons. The general agreement among the
States relative to announcing an end to regional load curtailment and
resuming normal utility operations.
C. Return to Normal Ooerations
Once the shortage is alleviated, the States and utilities must bring closure to the
curtailment process and effect a retum to normaloperations. The States willdetailthe
process for utilities to follow. The nature of the actions to be taken will be influenced by
the applicable stage of curtailment. At a minimum, the following types of activities need
to occur:
(1)Public lnformatlon. The public must be informed that curtailment is no longer
required and thanked for their assistance in alleviating the energy shortage.
Administrative Mattere. All curtailment astivities will officially cease as of the
date that curtailment orders are lifted bythe States. The States will provide
utilities with guidelines to bring closure to cuftailment activities such as:
exemptions and appeals, penalty assessments, curtailment incentives (if any),
and curtailment reports.
OfficialActions. State authorities willtake whatever action is required to
rescind any State orders for mandatory load curtailment.
SECTION VII. UTILITY LIABILITY AND FINANCIAL RELIEF
Utility Llabllity for Damaqes Resultinq from Mandatory Load Curtallment Ordered
by the States
State law in each of the four Pacific Northwest States provides for waivers of, or
exemptions from, liability in the case of utilities enforcing mandatory load curtailment
ordered by the States.
0
(2)
(3)
A.
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B. Treatment of Proprletary lnformatlon
Utilities shall treat individual account data developed pursuant to this Plan as
proprietary in accordance with standard utility practice and State law. lf State law
prohibits utilities from releasing consumer account information to the State, consumefti
seeking exemptions and/or adjustments shall expressly authorize such exchange for
the sole purpose of enabling the State to evaluate the appropriateness of utility
determinations regarding the exemption/adjustment requests.
C. Flnanclal Relief for Utllltlee
Utilities may seek financial relief from the extraordinary costs of curtailment. Such costs
might be recovered through established drannels including utility rate-case procedures
and BPA power sales contract provislons that compensate utilities for revenues lost as
a result of State-initiated load curtailments.
sEcTtoN vilt. ANNUAL REVTEW' POSTCURTATLMENT EVALUATTON, AND UPDATE OF
THE REGIONAL CURTAILMENT PLAN
At least once a year, the l.Xility Coordinator will convene a meeting of all four State Contacts
and interested utilities for the purpose of reviewing and updating this Plan and associated
Appendices. Upon completion of the review, necessary changes will be made, a list of
substantive changes prepared, and a revised plan issued.
Following a period of State-initiated load curtailment, the utility Coordinator, State Contacts,
and interested utilities will evaluate the succEss of the Plan in meeting the curtailment goals.
The results of the evaluation shall be reflected in a report that will be included in the
lmplementation Record. Changes may be made to the Plan as a direct result of this post-
cudailment evaluation. This post-curtailment evaluation may be combined with the annual
review.
To the extent the Plan is reviewed and approved wtthout substantive changes either as a result
of the annual review orthe post-curtailment evaluation, the utility Coordinator shall make the
identified editorial conections and issue the updated Plan. lf substantive changes are required,
the participants in the review process shall agree to a process to make the necessary
adjustments. The Plan willthen be updated in accordance with the agreed-upon process and
the changes included in Appendix G.
SECTION IX. DESCRIPTION OF APPENDICES
A. Reqlonal Electric Enerqy Curtallment Analvsls Model
Appendix A is a description of REECAM, the analyticaltoolthat will be used to evaluate
the status of the regional power system and analyze the need for region-wide
curtailment.
-31-
B. Curtailment lnformation
Appendix B is a llsting of the types of curtailment information that will need to be made
available by entities affected by this Plan. The Appendix identifies not only what needs
to be done, but who needs to do it, and to whom it needs to be made available.
C. Curtailment Measures
Appendix C is a listing, by sector, ol actions to be taken to achieve curtailments of
approximately 5%, 1O%, and 15%+. The listed measures are provided to give ultimate
consumers some guidance and ideas as to howto comply with State directives.
D. Utility Curtailment Reports
Appendix D is the standard form (with instructions for completing it) to be used by
utilities to report curtailment information to the tXility Coordinator or State Contacts for
the purpose of managing the curtailment. Data that is required for general analysis of
the cudailment will be included on the form. The data will be available for use by
interested parties.
E Contact lnformation Regaldlng the Utllity Coordinator. State Contacts. and Utllity
Contacts
Appendix E identifies the l.Jtility Coordinator, State Contacts, and Utility Contacts.
Contact information (addresses and phone numbers) are provided for each. The
identified individuals (or their altemates) will be responsible for implementing the Plan
on behalf of their respective organizations. utility Contacts are identified for each
regional member of the Northwest Power Pool.
F. State Statute Cltatlons and State Aoencles
Appendix F is the legal citation of the State statutes goveming load curtaitment and a
listing of State agencies involved in (1) curtailment planning and implementation and (2)
related utility matters.
G. Annual Updates to the Plan
Appendix G is a compendium of the substantive changes made to the Plan over the
years.
SECTION x. VOLUME ll: RELATED CURTAILI/IENT INFORMATION
(Note: lnformation for A-C below will be Included onc.e it has been made available.)
A. lndividual State Plans and Summary of the Differences amono the State Plans
Attachment ll.A is a copy of each State plan and a summary of the differences among
the State plans and this Plan.
€,2-
B. Utillty Plane
Attadrment ll.B is a listing, by State, of all dectic utilitios that have submltted
curtallment plans to the appropriate State body. Other rdevant Information (such as
date of the plan, where the plan ls filed, how copies can be acquired, otc.) ls also
provlded. Requirements regardlng the flllng of curtallment plane vary fom State to
State.
C. State Statutes
Attachment ll.C is a copy, by State, of applicable legislation pertaining to State-inltlated
curtailment.
May22.,19Fl2
c:\lc\plan\plan
€s
APPENDIX A
(REECAM)
OVERVIEW OF THE MODEL
Section l: lntroduction
The Regional Electric Energy Cudailment Analysis Model, REECAM, is a tool that decision-
makers will use to assess the need for curtailment of electric energy in the four-State region of
Washington, Oregon, ldaho, and Montana (the'region'). While electric utilities plan resources
to serve expected loads, shortages can still develop. Resources may not perform as
anticipated, and loads can grow faster than expected. ln spite of good planning and prudent
power system operation, regional cudailment rnay be required to alleviate a power shortage.
Pacific Northwest utilities rely principally on hydroelectric generation, thermal generation, and
energy imported from other regions to meet their loads. These generation sources and loads
are reflected in REECAM, a model designed to forecast the load/resource balance forthe
region over the mid-term planning horizon of &18 months. Should the model results show a
significant energy deficit during the study period, regional decision-makers will need to
determine the timing and amount of load curtailment required to bring the power system back
into load/resource batance.
Hydroelectric generation, primarilyfrom the Columbia River Power System, provides most of
the power used in the Northwest. Since the energy production capability of the hydro system
is highly dependent on precipitation, the aqtual electrical output of this power source can vary
significantly from one year to the next. The difference in power availability between a good
water year and a bad one is called 'non-firm energf and it can be more than 5,000 average
annual megawatts - enough to power a citythe size of Seattle for 5 years. (An average annual
megawatt is equivalent to 1 MW each hour over a 12 month period [12 MW-months] or
8,760 Mwh/year [8,760 being the number of hours in a year].) Since utilities plan to meet their
firm loads with firm energy, non-firm energy buffers the system against the energy deficiencies
that could result from firm load ovemrns or lost resources. However, in some years there is
virtually no non-firm energy, and load overuns or lost resources in those years could
potentially cause the region to experience an energy deficiency of such magnitude as to
require implementation of the provisions of the Plan.
Utilities can dampen the impact of both the seasonaland annualswings in hydroelectric power
production capability through the use of 'storage.' By storing water in reservoirs, utilities can
'shape'the hydroelectric generation potential so power can be produced when it is most
needed. (Hydro naturalflows are high in the spring and early summer and low in the fall and
winter, while regional loads are greatest in the winter.) However, because hydro storage
capacity in the Columbia is limited (it, like the non-firm potential, is approximately
5,000 average annual megawatts), a multi-year drought could stress the power system to the
point that Northwest utilities could not count on having stored hydro available to supplement
other power sources.
Atthough hydroelectric generation potential is the most significant and volatile element in the
load/resource equation, other components mayvary as well. Thermal generation may not
perform as expected. ln some years, outages of thermal plants dedicated to serving Northwest
loads have caused a loss of some 1,000 average annual megawatts relative to expected
production levels.
Likewise, a non-regional resource could be lost because of transmission problems or failure of
the resource itself. Such Ioss could reduce imports and impair a utility's ability to meet its
loads. Regional import capability is about 14,000 average annual megawatts, but only about
6,000 MW of that is available for 'opportunitf purchases. The rest is used for firm contracts or
it is othenadse unavailable due to maintenance outages.
Another source of uncertainty with respect to the load/resource balance lies in the load itself.
Unexpected load growth could exacerbate atenuous resource situation. lf extremely cold
weather were to materialize during a period of unanticipated high load growth, it is conceivable
that Northwest loads could be in the order of 1,500-2,0@ average annual rnegawatts greater
than forecasted.
ln short, significant disturbances in the load/resource equation, inespective of the cause(s),
could potentially lead to conditions that might cause the States to invoke the provisions of the
Plan. However, the mere existence of good water conditions (high natural streamflows and/or
ample supplies of stored water) would probably otfset problems with other generation sources
and/or load overruns, making it highly unlikely that the States would need to imptement the
provisions of the Plan.
Sectlon ll: Purpose of the Model
The purpose of REECAM is to provide regional utilities and State govemments with an analytic
toolto assist them in making decisions conceming regional load cuilailment and power system
operations du rin g protracted energy shortages.
A number of decisions need to be made at the time that curtailment is contemplated: ls
regional curtailment needed? lf so, when should the provisions of the Plan be invoked and
curtailment requested? How much curtailment should be requested? Should the requested
curtailment be voluntary or mandatorf
Once curtailment has been initiated, other questions arise. ls curtailment actually occuning?
ls the load/resource picture coming back into balance? lf not, what needs to be done to
address the problem? Does regional load curtailment need to be continued? When should the
curtailment be lifted?
It is vital to remember that while REECAM is an important tool, it is only a tool. Furthermore, ft
is not designed to give decision-makers precise guidance such as: 'lnitiate voluntary
curtailmenlot 12.6% for 5 months starting on November 17.' Rather, REECAM will generate
probabilistic information about the power system. Decision-makers will have to interpret the
model's output in light of the power situation as they perceive it and the curtailment guidelines
presented in section lV hereof. By anallzing the REECAM inputs as well as the output,
decision-makers can determine if a projected shortage could be alleviated by utility actions
A-2
such as increasing purchases from non+egional sources or modifying the operating schedule
of a regional power plant. lf not, ctrtailment will likely be required. While the model might
seem more useful if it generated athumbs-uplthumbsdown'answef as to the need for
curtailment, the truth is that the right answer cannot be known in advance, and a probabilistic
approach gives decision-makers a more comprehensive toolfor managing the uncertainties
they actually face.
Sectlon lll: Descrlptlon of the Model
A. Overulew of the Model
REECAM models the electric load in the region and the generation that is dedicated to
serving that load. The physical resources (hydroelectric and thermal resources) that
regional utilities rely upon are modelled as are electric energy transfers from outside the
region, including both firm and 'opportunitf transfers from British Columbia, the
Southwest, and the East.
REECAM is a broad-brush modelthat employs a probabilistic approach to forecasting
the regional load/resource balance. Some of the inputs are Tixed,'but most are
variable. For each variable input, there is an expected value and a'distribution'
associated with that value. The model adds the fixed inputs to the randomly setected
values of the variable inputs and calculates the resulting load/resource balance. This
process is repeated a number of times, generating a series of 'games' or altemative
load/resource scenarios. The model provides decision-makens with an overview of the
types of system conditions they might expect overthe next &18 months. From these
probabilistic scenarios regarding load/resource conditions, regionaldecision-makers
can make informed choices about the need for regional load curtailment.
REECAM models the region's ability to meet electric energy loads under a stressed
condition, that is, when the region's r€sources may not be sufficient to serve all of the
region's loads in the near term. Because it models a stressed condition, the following
simplifying assumptions are made:
(i) Regionalthermal resources, including high cost resources, are operating
to the extent they are not, or have not been, forced out of seMce;(iD Regional import capability is tully utilized to the extent that the interties
are available and energy lrom other regions is available;(iii) Storage reservoirs in the'Coordinated System'are being drafted to meet
load to the extent permitted bythe Pacific Northwest Coordination
Agreement (PNCA); and(iv) Besources and loads are modelled as if the region were served by a
single utility. (Because REECAM is a regional model, inter-utility transfers
are not explicitly modelled.)(v) Regional non-firm loads are already otf{ine to the extent permitted by
contract.
A-3
B. Description of lnputs to the Model
There are seven basic inputs to REECAM: regionalfirm loads, non+egionalfirm sales,
hydro naturalflows, hydro storage, thermal generation, energy imports, and
miscellaneous resources. Two of the inputs, non-regional firm sales and miscellaneous
resources, are input as Txed'values. Hydro storage is input at its cunent value as of
the time the study is run; subsequent values for hydro storage throughout the study
period are calculated as 'residuals'with respect to the other model inputs. The four
remaining inputs - regionalfirm loads, hydro naturalflows, thermal generation and
energy impods - are distributions that are incorporated in REECAM. The distributions
for these lvariable' inputs reflect normal forecasting uncertainties. REECAM selects
values lor each of the four tariable' inputs from these distributions for each study
period.
It is quite possible that one or more of the inputs will be affested by non-random factors
that are known at the time the study is run but cannot be predicted in advance and built
into the model since they do not generally apply. For example, a power plant or
transmission line may be out of service for an extended period due to an earlier forced
outage. lt is vitalthat such events be expressly reflected in the modelling process, as
they will have a significant bearing on the need for cudailment. Wthin the modelthey
are handled through the use of 'adjustment'factors which, in essence, override the
normal algorithm applicable to the atfected input(s).
The seven basic inputs are discussed below in more detail.
(1) Reolonal Firm Load
Two ditferent load forecasts comprise the 'regional firm load' component of the
model. The first is BPAs forecast of firm regional utility and FederalAgency (FA)
load. (All FederalAgencies are included in this forecast including the loads of
agencies served under rnetered requirements power sales contracts and the
USBR reserued power loads.) Federaltransmission system losses are also
included in the utility/FA forecast. The second forecast is the firm poftion of
BPAs d irect-seMce ind ustrial customers' load.
ln making the utility/FA forecast for REECAM, BPA begins with a forecast of firm
utility and FA loads in the region as defined in the NW PowerAct, slightly
modified so asi to include all ol Montana Power Compant's (MPC)total system
Ioads (i.e., adding the loads east of the Continental Divide) [Modified Forecast].
This Modified Forecast is then adjusted to anive at a forecast for the four-State
area which comprises the 'region' as defined in this Plan. There are two
adjustments: MPC's load is increased to reflect its totalcontrol area loads (not
just its totalsystem loads), and BPAs firm utility loads in non-regional States
(Califomia, Nevada, Utah, and Wyoming) are removed from the Modified
Forecast and included in the'non-regionalfirm sales'input. To the extent that
PacifiCorp's loads fall within the four-State area comprising the'region'as
defined in the Plan, they are included in the regionalfirm load input. Hence
PacifiCorp's loads in the State of ldaho are included in the forecast of regional
firm load, while its California loads are reflected in the'non-regionalfirm sales'
A-4
input. ffhese loads must be modelled because they are served with 'regional'
resources.)
The industrial load is separated from the utility/FA load for forecasting purposes
because it is influenced by different factors. The utility/FA load is primarily
affected by weather and regional economic conditions, whereas the industrial
load is also highly sensitive to product prices. Both loads are significant in size
(the utili[/FA load being 17,000 average annual megawatts and the industrial
load being 3,000 average annual megawatts).
BPA forecasts regional lirm utility/FA loads using an econometric model that
produces a'medium'case forecast. The forecast is short-term in nature and is
initialized at 'actual'values at the time the study ls run, based on BPA and
NWPP data. The studies used to generate the forecast take into account cunent
load trends and near-term economics. General projections of near-term weather
trends (up to 2 weeks) may be included through application of adjustment
factors, although weather projections beyond a7 day period are highly tenuous.
BPA uses Monte Carlo simulation to modelthe uncertainties associated with
weather and regional economic conditions over the study horizon. The resulting
probability distribution around the medium case forecast is used as a basis for
selecting five altemative regional utility/FA load forecasts (low, medium-low,
medium, medium-high, and high). Each of those five forecasts has an
associated probability of occunence. The forecasts and identified probabilities
are input to REECAM, and the probabilities are taken into account by REECAM
when a load within the forecast range is randomly selected as the load'for a
particular 'garne.'
BPA uses a different approach to forecasting the industrial loads. Load
forecasts for the region's aluminum producers are based on an analysis of
aluminum prices and production costs and consideration of a number of factors
that are not price-related. Other industrial loads served by BPA are forecasted
on a plant-byplant basis, taking into account economic and technicaltrends
applicable to their respective industries. lndustrial loads are initialized at cunent
operating levels. To generate the alternative industrial load forecasts, BPA
changes the underlying assumptions, making them more pessimistic in the'lou/
and'medium-louf cases and more optimistic in the'medium-high'and 'high'
load scenarios. Probabilities are assigned to each of the five load forecasts.
The actual industrial load inputs to REECAM are not the five industrial load
forecasts per se, but rather the five forecasts adjusted to reflect the amount of
load that BPA projects it will be seMng during the shortage period.
(2) Non-Reqlonal Firm Sales
HEECAM atso includes an input lor non-regionalfirm sales. This input is
comprised of three basic components: (1) sales to extra-regional entities as that
term is defined in section 3.(14) of P.L. 95-501 (the NW Power Act);
(2) wholesale sales to BPAs non-regionalfirm loads (including sales to all, or a
A-s
portion of, the loads ol the following utilities: Surprise Valley Electric Coop in
California, Harney Electric Coop in Nevada, Wells Rural Electric Coop in
Nevada, Raft River Electric Coop in Nevada and Utah, and Lower Valley Power &
Ught in Wyoming); and (3) retailsales to PacifiCorp's Califomia loads served
with resources dedicated to serving Northwest loads. These three loads are
identified on a spreadsheet, and the spreadsheet totals are input to REECAM.
No forecasting uncertainty ls assumed with respect to any of these Non-
Regional Firm Sales; hence this input ls treated as fixed (although the values will
vary by forecast period).
(3) Hvdro Natural Flow
The ability of the hydroelectric power system to generate energy is determined
by two factors: hydro naturalflows and hydro storage. The convention among
power planners is to use forecasted streamflow at The Dalles as a benchmark
for naturalstreamflow in the entire Columbia River Power System. The
streamflow, which is measured in thousands of cubic feet per second (kcfs), is
converted to an estimated power production figure (average megawatts) using a
formula specified in REECAM. This formula accounts for all hydro projects in
the'Coordinated System.' (Ihe Coordinated System includes all hydroelectric
projects in the region except forthose belonging to ldaho Power Company and
those that Montana Power Company excludes from PNCA planning because
they are located outside the'region,'as that term is used by PNCA parties.)
Hydro natural flows comprise one of the five 'resourc€' elements in REECAM's
load/resource equation. The manner in which the streamflow is forecast for
REECAM depends upon when the forecast is rnade.
The period Januarythrough July is often refened to as the'refill'period.
REECAM forecasts prepared ln the period January through July for the
immediate refill period wil! be based on the latest forecast of the January-July
volume runoff at The Dalles. The volume forecast is normally expressed in
million-acre-feet, or MAF. The forecast for The Dalles is really a composite ol
volume forecasts for each river basin compdsing the Columbia River Power
System. Unceilainty as to acf,ual streamflow conditions will be modelled by
applying the Standard Enor of Estimate for each forecast period (typlcally one
month). The forecast volumE will be shaped among periods according to the
normal streamflow distribution unless better information is available at the time
the forecast is made. Natural streamflows, measured in kcfs, are calculated
from the volume forecast lorthe period by multiplying the forecast by a
conversion factor of 504.167 and dividing by the number of days in the forecast
period.
The period August through December is generally known as the 'drawdown'
period. utilities can reasonably forecast streamflours for two months into the
future. Beyond that, forecasting uncertainty becomes too great to assume
anything but'normal'streamflows. As with other input data, the'best available'
information is used to derive the streamflow forecast. Hence, REECAM's
streamflow forecasts (other than those made during the refill period for the same
A€
refill period) use estimated data in the nearterm and'normal'streamflow data
forthe remainder of the lorecast period. Streamflow uncertainty will be
modelled through the use of statisticalfactors derived from the streamflow
statistics generated by the latest historical record, cunently the 50 years
between 1 92&29 and 1977-78.
A'smoothing'routine is built into the program to even out the dramatic
streamflowfluctuations that would likely occur if purely random statistical data
were used to model streamflow values.
(4) Hydro Storaqe
Hydro storage plays an important role in the regional power system. During
periods of high naturalflows, when the water coming unencumbered down the
river could generate more energy than is needed at the moment, the excess
water can be stored in reservoirs and held for luture use.
To understand the hydro storage component of REECAM, it is important to
recognize that utilities must cooperate with each other to optimize the output of
the hydro system. Much of the generating capability of the hydro system would
be lost if utilities operated their hydro projects independently. Water would be
spilled unnecessarily at downstream projects due to the actions of upstream
parties, and power might not be available when needed. The PNCA is the
contract that govems operation of the hydro system and releases from hydro
storage.
Under the PNCA, the parties calculate the region's annual firm energy load
carrying capability (FELCC). FELCC represents the maximum amount of power
that the Coordinated System can produce under crttical water conditions. Since
this amount of power can be actieved only if the parties coordinate their
operations to optimize total system output, the hydro system is managed so as
to'develop' the annual FELCC.
The region's FELCC is allocated to PNCA parties according to the amount of
FELCC that is generated by their respective resources. The annual FELCC is
shaped by period to match the expected load shape overthe year. The load
shape for each period essentially becomes the larget'lor system operations,
and the reservoirs are operated in such a way as to produce the period's
FELCC. Utilities use their FELCC to meet their loads.
lf actual loads are higher than the period's FELCC (including both the hydro
FELCC and thermal FELCC), utilities must acquire energy from other sources to
meet the excess load; if loads are lower, utilities can market unneeded FELCC
or generate less than FELCC and store the unused water. Water is'drafted'or
released from storage and used to generate energy whenever the hydro
component of the period's FELCC exceeds the amount of power that can be
generated from hydro naturalflow. Likewise, when the naturalflow component
provides surplus relative to sales, storage wil! be filled. (Generating more firm
power than the designated FELCC in order to meet actual loads coutd result in a
k7
net loss ol luture power production capability; hence, the system is operated to
produce the period's FELCC.)
Storage in REECAM is modelled as one dam with the full storage capability of all
the region's storage reseryoirs available underthe PNCA. The modeltakes into
account normal operating constraints such as the physical limits of full and
empty. The modelalso considers otherfactorc that affect access to stored
water, including flood control requirements, fish operations, and non-firm energy
sales.
Within HEECAM, generation lrom hydro storage is determined by subtracting
generation from hydro natural flows from FELCC. lf the resulting hydro storage
value is greater than permitted by the physlcal limits and operating constraints of
the system, then any exc€ss water is spilled. lf the resulting hydro storage value
is so lowthat it would result ln the system being drafted below permissible
levels, the hydro storage input will reflect that fact and the difference between
the calculated hydro storage value and the lowest permissible value is registered
as the regional load/resource deficit for that particular period.
(5) Thermal Generation
The thermal resource component of REECAM is derived from a separate mode!,
one that analyzes the power production capability of each thermal resource
dedicated to serving regional load. Uke REECAM, this modelis probabilistic in
nature. The output of this thermal model is a forecast of regional thermal power
production capability. By running a number of games, it is possible to develop a
spectrum of altemative scenarios regarding thermal plant performance. These
thermal model output data are input to REECAM.
The thermal model forecasts regional thermal power prod uction capability,
taking into account three factors: the generating capability of each plant, the
forced outage rate for each plant, and planned maintenance outages.
'Generating capabilitf is simplythe energy capability of a plant as repofted by
the utility that is responsible for its operation. The generating capability figure
represents the maximum amount of energy a resource could produce on an
ongoing basis (the 'maximum continuous rating'for the plant), assuming no
forced outages and no down-time for normal maintenance.
LJtilities use the term Torced outage'to describe the unexpected loss of a
resource. Each plant analyzed in the model is assigned aforced outage rate
based on the best available data for that plant or plant type. Many utilities
develop plant-specific forced outage rates based on the plant's operating
history. ln the case of plants for which there is no plant-specific data, a forced
outage rate that is 'typical' of similar facilities is used. These 'typical'values are
taken lrom statistics published by NERC, the North American Electric Reliability
Council. (See NEBCs Generating Availability Data System.)
A-8
The thermal model dso takes planned maintenance outages into account by
reducing plant output to reflect down-time during routine maintenance periods.
(6) lmports
Energy imported into the region is an important resource consideration in the
REECAM analysis lortwo r@sons: (1) some utilities rely on impods, at least in
part, to meet their native load, and (2) 'opportunrty' imports to the region are a
major factor in the system's ability to survive an adverse operating situation.
There are intenegional interties to the East into Montana and Wyoming, to the
North into Canada, and to the South into Califomia and the'lnland Southwest'
(Arizona, Nevada, and New Mexico). These interties can bring large quantities
of energy into the region should the need arise. The undiminished regional
import capability is approximately 14,@0 average annual megawatts, but
approximately two thirds of that capability is already in use, being devoted to
firm contracts. These firm contracts for energy imports are identified on a
spreadsheet; the total of all such contracts are input to REECAM as one element
of the 'import' component of the model.
What import capacity remains may be used for opportunity transfers, which is
the other element of the'import'component of the model. Opportunitytransfers
are limited by two factors: (1) transmission availability and (2) energy
availability.
Transmission availability is treated as an input to REECAM. Avaitability is
determined by ascertaining each line's cunent operating capability (based on
recent historical use) and subtracting both capacity reserved for delivery of
power under existing firm contracts and unusable capacity due to down-time for
maintenance orforced outages. Forced outages are factored into REECAM
based on a probability distribution derived from historicalforced outage rates.
Energy availability is also an input to REECAM. At the time that REECAM is run,
non*egional energy availability will be estimated from information provided to
the modellers by the region's utilities.
(7) Miscellaneoue Resources
The 'miscellaneous resource' input captures the effects of a variety of resource
variations that are not otherwise reflested in the model. Among the fastorc
included in the miscellaneous resource input are: non-treaty storage, Flexibility
and Provisional drafts as provided in the PNCA, and resources that are not
otherwise modelled (such as ldaho Power Company's hydro resources,
Montana Power Company's hydro resources that are not included in PNCA
planning, and any other resources that are not othenrise modelled, but are in
lact used to serve regional loads.) Also included in the miscellaneous resource
category is an amount equal to PacifiCorp's load in ldaho served by the Utah
division. The power to serve this load comes from non+egional sources. By
including a resource in the amount of the load, the model effectively'nets out'
A-9
the regional load that is served with non-regional resources. The individual
components of the miscellaneous resource input are identified on a
spreadsheet, and the spreadsheet totals are lnput to REECAM. This input is
treated as lixed;' no uncertainties with respect to miscellaneous resources are
modelled.
C. Descriptlon of Model Outputs
Each REECAM game generates an output ln the form of a regional energy surplus or
regional deficitfor each month or altemative study period overthe study horizon. This
output is calculated by subtracting load (the sum of the two load inputs) from resources
(the sum of allfive resource components). To ensure REECAM's outputs are a
statistically valid representation of their range of uncertainty, each run is comprised ol at
least 1@ games. Each REECAM run is designed to give energy planners and regional
decision-makers an accurate picture of the load/resource situation they are facing.
The output for each REECAM game is based on a selection of input dataforthe seven
REECAM inputs: regionallirm loads, non+egionalfirm sales, hydro naturalflow, hydro
storage, thermal generation, import capabllity, and miscellaneous resources. The two
fixed components of the model, non-regional firm sales and miscellaneous resources,
are input at their established values, and the same values are used in all games. The
hydro storage generation component ls calculated by subtracting hydro naturalflows
from the amount ol the regional FELCC for each study period. The input data for the
variable components of the modelare randomly selected from probability distributions
designed to ensure that proper weight is given to the more likely scenarios.
A complete REECAM study includes the numerical output from individual games as well
as a histogram summarizing that data. The REECAM output histogram shows
'probability of occunence' on the vertical axis and size of the resource deficit or surplus
on the horizontal axis. The probabilities shown on the graph willalways sum to 100%.
For a sample REECAM output, see Figure 1.
REECAM can also generate frequency histograms from the input data. The input
histograms are useful in that they provide power analysts and regional decision-makers
with an understanding of the causes of anticipated deficits. These histograms
summarize the information contained in the input files. The vertical ods of the chart
reflects the probability of a certain load or resource performance. The horizontal a,xis
on an 'input'histogram shows the size of the load orthe amount of generation
produced by the resource. As with the output histograms, the probabilities reflected on
the vertical axis sum to 100%. Figure 2 provides a sample histogram for one REECAM
input, thermal generation.
D. Study Perlod / Study Horizon
REECAM will normally be used to generate monthly forecasts of the regional
load/resource balance. The model is flexible, however, and can generate data for
periods of any length (daily, weekly, monthly, bi-monthly...).
A-10
Normallythe study horizon will not exceed 18 months. Although it is possible that
planners might want to examine REECAM results for a longer period, the model is most
accurate in the near-term. Load/resource balance uncertainty increases dramatically
over time, and the study results become conespondingly less and less meaningful.
Section lV: Use of the REECAM Output
As mentioned earlier, REECAM is atool. lts purpose is to provide power analysts and regional
decision-makers with information that will help them to make appropriate decisions regarding
the need for near-term regional curtailment to maintain power system reliability at acceptable
!evels.
A. Ooerational Uses of REECAM
Utilities may find it prudent to adjust their system operations in light of the results of
REECAM. Utilities have a great deal of control overthe amount of powerthat is
impofted to the region as well as the timing of those imports. The import factor could
have a significant influence over the need for firture curtailments. REECAM will provide
utilities with a good understanding of the risks and benefits of various import
altematives.
The REECAM results may also be used by utilities in making operating decisions about
their thermal plants. REECAM may help operators decide wtren to begin to run their
discretionary, usually high cost, thermal plants. l.Jtilities may also choose to adjust their
maintenance schedules based on the REECAM results.
B. Curtailment Decisions
From the input and output histograms, it is possible to get a picture of what'might be'
with respect to the load/resource balance over the next year or so. lf the picture
appears overly wonisome, especialty in light of other factors being considered by the
decision+nakers, either load curtailment or some sort of change in resource operation
would be indicated.
There is no 'absolute' with respect to interpretation of the model's results. However,
power analysts will propose guidelines for regional decision-makers to consider when
reviewing REECAM results. The REECAM output will assist decision+nakers in
answering the following types of questions:
1. Need for Curtailment
Should regional load curtailment be imposed if there is more than a _%
probability that a regional deficit of at least _ megawatts will materialize
and last for more than months?
Should regional load curtailment be imposed if there is more than a _%
probability that a regional deficit of at least _ megawatts will materialize
next month and if the megawatt import capability for that rnonth is less
than the amount ol the deficit?
a.
b.
A-11
2. Selection of Curtallment lBvels
Before the appropriate curtailment level can be determined, the load/resource
deficit as determined from REECAM must be expressed relative to the weather-
normalized Base Year load. This ls an important step because consumers will
be asked to curtail relatfue to thelr use ln the Base Year, ratherthan relative to
their present consumption. lf consumers have changed their energy
consumption habits overthe last year, failure to make this adjustment could
result in a callforthe wrong amount of curtailment.
There are other lactors as well that will affect the percentage curtailment
required in order to bring the systern back into load/resource balance.
One such factor is load grouiltr. Consumers that have moved into the region
over the last year will also be curtailing their loads, and their presence ls not
reflected in the Base Year data. This factor should have the effect of reducing
the percentage curtailment required from regional consumers.
A factor that will drive the required curtailment percentage upwards is the fact
that Non-Begionalfirm sales are not subject to curtailment. Hence, regional
consumerc must provide an additional increment of savings to cover utility
responsibilities with respect to seMng those other loads.
A final factor that will affect the load/resource balance is one that cannot be
forecasted;that is, weather conditions. REECAM is based on an assumption of
'average'weather, and the amount of required curtailment required will be less if
the weather is mild, and more if the weather is extreme.
Regional decision+nakers will need to take allthese variables into account when
deciding the appropriate level of load ctrrtailment to request from Pacific
Northwest consumers.
A-12
ProbaH[ty
Occunence
ProbaHfity
Occunence
of
50
45
4
35
30
%
N
15
t0
5
0
FIGIURE t
I II I
-1000 -500 0
SurplusTDeficit
FIGUBE 2
5450 5f50 6(m
500 1000
30
6
n
15
10
of
5
0
5(m 55q)
A-13
Thermal Generatlon
APPENDIX B
TYPES OF CURTAILIT/IENT INFORMATION
This Appendix describes the types of activities that will need to take place during load
curtailment and the parties most likely to be responsible for them. Final decisions about roles
and responsibilities will be made at the time that curtailment is actually imposed.
A. Public lnformation Process
Statewide public information strategies generally should be coordinated by the States.
Utility-specific public infonnation should be consistent with, but not limited to, the public
information provided by the States.
Each State should
Convene a working group of State, utility, and media representatives to develop
public information strategies.
Convene a working group of State and local government representatives to
develop instructions for addressing hardship and grievance cases. Such
instructions are for public dissemination.
Convene a working group of State and utility representatives to calcutate
curtailment impacts. lmpacts assessments are needed for both decision-
makers and the public.
B. Types of Arnouncements and/or Reports
General announcements of curtailments;
Periodic regional and utility-specific situation reports (system conditions);
Periodic implementation reports (curtailment results and impacts);
Background reports and responses to media requests;
Emergency, hardship, and/or grievance instructions;
Exemption and adjustment instructions; and
Electricity consumption reduction handouts.
C. Responsibilities for Developing and Disseminating Curtailment Information
1
2.
3.
1.
2.
3.
4.
5.
b.
7.
Responsibilities for developing and disseminating this information to appropriate parties
are as follows:
1 General Announcements of Curtailment
a. State Role:
(1)
(2)
(3)
(4)
b. Utility Role:
Notity media of utility implementation of curtailment orders.
Notity consumers of curtailment conditions.
Provide consumers with State-prepared materials regard i n g
enforcement of mandatory cudailment.
Periodic Reoional and Utility Specific Situation Reports (routinely provided
to the Northwest Power Planninq Council)
Utility Coordinator Role:
(1)
(2)
(3)
Formally notify utilities of initial and subsequent curtailment
stages and levels.
Notity media of curtailment conditions.
Make public announcements of curtailment conditions.
Prepare materialto provide to utilities as bill stuffers explaining
the purpose of mandatory curtailment, describing how curtailment
will be enforced, and outlining the penalty provisions of the Plan.
Notify media of regional and Statewide electric system conditions
Notity critical users and energy producers of regional and
Statewide electric system conditions.
2.
Collect, aggregate, and provide States and utilities with information
about specific utilities and regional electric system conditions.
b. State Role:
a.
(1)
(2)
c.Utility Role:
(1) Provide l.Xility Coordinator with information about utility-specific
electric system conditions.(21 Notify customers and media of utility-specific electric system
conditions.
3. UtiliU Curtailment Report
Utility Coordinator Role:
Collect, aggregate, and provide States and utilities with data regarding
curtailment impacts and the progress that has been made. Curtailment
data must be available by utility and for the region as a whole.
a.
*2
b. State Role:
Calculate Statewide impacts (energy impacts, economic impacts,
etc.).
Provide other States wtth Statewide impac{ assessments.
Notify media of regional and Statewide curtailment progress and
regional and Statewide impacts.
c.Utllity Role:
(1) Provide the LJtility Coordinator with utility-specific curtailment
progress (use tltility Curtailment Beport Form).(2) Notify consumers and the media of utility-specific curtailment
progress and local impacts.
4. Backoround Reports and Responsee to Medla Requests
a. Utllity Coordinator Role:
(1) Prepare and provide States and the media with technical
background information as requested.(2') Provide copies of the Regional Plan to all requesters.(3) Respond to media requests for information on regional issues.
State Role:
Prepare and provide technical and policy background information
to the media and public as deemed neoessary or requested.
Provlde State and Regional Plan to all requesters.
Respond to media requests for information on regional and
Statewide issues.
c.Utility Role:
(1) Provide technical and policy background information to the media
and public as requested or direct inqulries to State.(21 Bespond to media requests for information on utility-specific
issues.
5.Emeruency. Hardehio. or Grlevance lnstructlons
a. State Role:
(1)
(1)
(z',)
(3)
b.
(1)
(21
(3)
(21
(3)
(4)
Determine specific pro@sses lor handling emergency health and
safety concerns, hardship and grievance cases.
Determine the best strategyfor disseminating such instructions.
Provide utilities and the media with process information.
Provide process information to the public through hotlines.
&3
6
b. Utility Role:
(1) Provide allconsumers with specific information about processes
lor handling emergency health and safety concerns, hardship,
and grievance cases.(21 Provide such information to the media as requested.
Exemption and Adlustment lnstructlone
a. State Role:
(1)
(21
(3)
Prepare and provide utilities with guidelines for determining the
appropriateness of granting exemption and adjustment requests.
Provide the media with generic exemption and adjustment
information.
Provide the public with access to exemption and adjustment
information (through the use of publications, hotlines, etc.).
b. Utility Role:
Notity consumers, as necessary, of the exemption and adjustment
process.
7. ElectricityConsumptlonReductionHandouts
a. State Role:
Determine appropriate consu m ption red uction m easu res with
utility input.
Print handouts with assistance of utilities.
Provide the media with handouts.
Provide access to handouts through hotlines.
b. Utility Role:
(1) Assist their respective States in determining appropriate
consumption reduction measures.(21 Print handouts with the assistance of the State.(3) Provide the media with handouts as requested.(4) Provide all consumers with appropriate handouts.
(1)
(2)
(3)
(4)
&4
APPENDIX C
CURTAILMENT MEASURES
Curtailment measures will be dependent upon manyfactors, lncluding geographic sub-areas of
the Pacific Northwest (some have healy air condiUoning loads or inigation loads, while others
do not); the time of year (residential space heating and lighting are seasonal, as are air
conditioning loads); industrialversus non-industrial areas; and so on.
These curtailment'packages'are intended to be illustrative only, and @! prescriptive. Many
combinations of measures could be utilized to accomplish the curtailment goals. Each State,
within its own administrative and consumptive struc'ture, will need to determlne the most
appropriate mix consistent with time of year, local economies, public health considerations,
and other factors deemed essential to the curtailment process.
Each plan should also be sensitive to the possibility that through conservation and other
efforts, some electric consumers may already be at a minimal level.
To Achleve Approxlmately a 5% Curtallment:
Residential:. Reduce space heat to 65 degrees F;. Utilize night set-backs (10 degrees recommend"O);. lncrease air conditioning to 80 degrees F if in cooling season;. Heduce lighting 2O96, either by tuming off U5 of lights regularly on or
reducing total light wattage by 1/5 (replace all 75-Watt wtth 6&Watt, for
example).
Commercial:. Reduce space heatto 65 degrees F;. Utilize temperature set-backs during times the business is closed;. Increase air conditioning to 8O degrees F if in cooling season;. Reduce Iighting 2096, either by tuming off every Sth light regularly on or
reducing total light wattage by U5.
lndustrial:
a DSI's and non-DSl's cut 5% of load as decided intemally - processes, shift
scheduling, lower power settings on machlnery, etc.
lrrigation:. lf during inigation season, shut off pumps t hour of pumping time each day
(if pumping 24 hours a day), or trade{n for 5% lower wattage pumps.
To Achieve Approximately a 10% Curtailment:
Residential:o All steps of the previous level;o lncrease air conditioning to 85 degrees F if in cooling season;. AdditionalS% lighting reduction (total25% - replace 6o-Watt with 4$Watt);. Set water heaters at 130 degrees F (if higher);. Reduce all other electricity use 5% (with some of the following measures):. shut down hot tubs, home spas, swimming pool heaters,. restrict clothes dryer use,. tum up refrigeratortemperature to 3840 degrees F,. limit use of automatic timers and clocks,. reduce water bed heater temperatures,. reduce electric blanket settings,. cook with microwave versus electric resistance ovens.
Commercial:o All steps of the previous Ievel;. lncrease air conditioning to 85 degrees F if in cooting season;. Additional 5% lighting reduction (total 25% reduction, every 4th light off);o Eliminate advertising, reduce parking lot lights (not necessarily security
lights);. Set water heaters at 130 degrees F (if higher);. Reduce all other electricity use 596, depending on type of commercial
establishment:. eliminate clothes dryer use,o tum up refrigeratorfireezer temperatures,. limit use of automatic timers and clocks, etc.
Government/Utility:o Tum off 1/3 outdoor street lights and parking lot lighting;. Reduce 10% of own buildinglfacility electricity consumption however
determined by facility management.
lndustrial:
o DSI's and non-DSl's cut 10% of load as decided intemally - processes, work
shitts, machinery, etc.
lrrigation:. lf during irrigation seasonr shut off pumps 2-112 hours of pumping time each
day (if pumping 24 hours), or trade-in lor 10% lower wattage pumps.
c2
To Achieve Approximately a 15+% Curtailment:
Residential:. All steps of previous level;o Reduce space heat to 62 degrees F if all household members healthy;. Additiona! 5% lighting reduction (total 30%: 1/3 of all lights removed, and no
wattage greaterthan 4GW); alloutside lighting off;. Turn down water heaterto 120 degrees F (if higheQ;'*'l'*H$1ffi*T**".
:::: ""
Commercial:. All steps of previous level;. Additional 5% lighting reduction (tota! 30%: 1/3 of all lights removed, all
security lighting off);. Eliminate advertising, parking lot lights;. Turn down water heater to 120 degrees F (if higher);. Reduce all other electricity use additional 15% (for a total reduction of 15%) -
reduce pump and compressor use, raise freezer temperatures, limit use of
automatic timers and clocks, etc.
Government/Utility:. Turn otf all outdoor street and parking lot lighting;. Allnon-DSl Federal loads cut 15% (military, Bureau of Reclamation, BIA);. Reduce building/facility electricity consumption a total of 15%.
lndustrial:
a DS!'s and non-DSl's cut 15% of load as decided intemally - processes, work
shifts, machinery power, etc.
lrrigation:
a lf during irrigation season, shut otf pumps 5 hours of pumping time each day
(if pumping 24 hours each day), or trade-in for 15% lower wattage pumps.
APPENDIX C REFERENCES:
BPA, Pacific Northwest Loads & Resources Study. Podland, OR; BPA, annually.
BPA & Northwest Power Planning Council, Economic Forecasts forthe Pacific Northwest.
Portland, OR; BPA & NWPPC, 1988.
c-3
APPENDIX D
UTILIW CURTAILMENT REPORT
Utllity Oblloatlon to Provlde Curtallment Data
At alltimes during State-initiated regional load curtailment, utilities shall be prepared to provide
their respective States and the tXility Coordinator wtth consumption and savings data on a
monthly basis in the lorm specified below. Priorto the initiation of load curtailment, the States
shall determine due dates for these monthly reports and so inform the utilities within their
respective jurisdictions.
Value of a Sinole Standardized Report
By adopting a common curtailment savings reporting form for use by utilities in allfour States,
the States are ensuring that:
(a)Utilities Are Prepared for Curtallment. All utilities in the region should be
prepared at any time to provide the data that the States need to evaluate the
etfectiveness of the load curtailment directive. (By specitying the filing
requirements in this Plan, the States are giving utilities time to develop the
necessary administrative tools to enable them to generate the required data
from the beginning of State-initiated load curtailment, inespective of when that
curtailment may occur.)
(b) Curtailment Data le Conslstent Among Utillties. The datathemselves will be
more @nsistent among utilities sinc-e the form will prescribe a specific manner of
reporting that may differ from how the utility would otherwise choose to repoft.
Use of the standardized form willgive regional planners a more ceftain grasp of
the impacts that requested load cudailment is having on the regionalenergy
situation; without it, reported impacts in one State or in one utility's service area
might appear substantially different from the impacts in another, inespective of
the reality of the situation; and
(c)Curtailment Admlnlstratlon ls Facllltated. Those individuals that need to work
with the data (State personnel, utility personnel, and the Utility Coordinator) will
be able to do so with a minimum of dfficulty since it is easier to work with data
presented in a common format than with data presented in a variety of tormats.
(d) A Common Data Base of Curtallment lnformatlon ls Establlshed. By having
all Pacific Northwest utilities submit curtailment information on the same form
and by giving all parties that need curtailment information a voice in
development of that form, a single data base with all relevant curtailment
information can be established. Having a single comprehensive source of
curtailment data will minimize the amount of data collection that will be required.
Multi-State utilities will need to fill out the form for each State in which they serve,
but the data collection and reporting process will be simplified by virtue of using
the same lorm for each State. Data from this report can be used for a variety of
purposes. For example, thls data base can be used by the l.Jtllity Coordinator to
assess the success ol curtailment efforts to date, it can be accessed by States
preparing reports to their respective State agencies and govemors, and it can
be used by BPA to determine lost re\renu€ payments to utilities under their
power sales contracts.
The information requested on the Utilrty Curtailment Report is both necessary and sufficient for
curtailment administration as Jointly determlned by representatives of the States, Paciflc
Northwest utilities (including BPA), and the NWPP. To the odent a need for additional
information arises (or certain information tums out to be unnecessary), the standardized LXility
Curtailment Report will be modified.
D-2
ffi!ffi LOCATION OF SERVICE AREA (Check one)
[.;.iW,e$ry
REGIONAL UTILITY CURTAILMENT REPORT FORM
PART l: ORIGINAL FILING INFORMATION
PRIMARY AND ALTERNATE CONTACT PERSON
TOTAL NUMBER OF CONSUMERS IN SERVICE AREA
D-3
REGIONAL UTILITY CURTAILMENT REPORT FOHM
PART II: MONTHLY INFORMATION
SPECIFIED CURTAILMENT PERCENTAGE LEVELS
LOADS DURING REPORTING PERIOD (ln MWhs)
WEATHER ADJUSTED CONSUMPTION LEVEI-S (in MWhs)
COMPLIANCE
NUMBER OF CONSUMERS WITH PENALTIES ASSESSED
D-4
Adiustments Granted by State
REGIONAL UTILITY CURTAILMENT REPORT FORM
PART II: MONTHLY INFORMATION
EXEM PTIONS/ADJUSTM ENTS
D-s
REGIONAL UTILITY CURTAILJI/IENT REPORT FORM
INSTRUCTIONS
-
GENERAL
The Regional Utility Curtailment Report Form must be filed each month during State-ordered
curtailment. lt is anticipated that this information will be filed electronically via a
spreadsheeVdatabase program developed speciftcallyforthis report, and provided to each
reporting utility. However, hard copies willstill be required to provide documentation and
backup in the event of data loss orfailure. Each utility must provide a separate report to the
State Contact of each State (in the region) in which they provide service. Utilities must also
provide a copy of each report to the LXility Coordinator. The names and addresses of the State
Contacts and the tXility Coordinator are provided on the last page of these instructions.
Utilities are also advised to keep copies of these reports fortheir own records. The information
provided will be used to assess the effectiveness of the curtailment effort, to determine ways to
enhance curtailment productivity, to insure that consumers are being treated as uniformly as
possible throughout the region by various utilities, and as a historical record of curtailment
activities. The analysis of the information provided on this form will enable the States and
utilities to determine ways of improving their curtailment plans in the future, or to document the
success of the plan in areas where changes are not indicated.
PART l: OHIGINAL FILING INFORMATION
Part I of the Regional Llility Curtailment Report Form will be filled out at the beginning of any
State-initiated load curtailment. lt will probably not need to be revised during the curtailment
period, unless the utility decides to designate a different Contact Person, the information about
the Contaqt Person changes, orthe utillty has modified its procedures in such a way as to
cause the answers to the questions on the lower portion of the form to change. A copy of the
original Part I (or a new Part I if the lnformation has changed) must be included with Part ll
when it is filed monthly with the tXility Coordinator and the States.
(1) NAME OF UTILITY: Enter your compant's official name, or the name by which your
utility is commonly known in the region. For example, 'Public l.Xility District of Grant
Countf may be also be entered as'Grant County PUD'. 'Puget Sound Power & Ught'
may also be entered as'Puget Powef or'PSP&L'.
(2) FEPORT DATE: Enter the date that you are filling out the report, or the date that you
complete the report if it takes more than one day.
(3) PRIMARY AND ALTERNATE CONTACT PERSON: ln the first table, enter the
information forthe person that your utility has designated as the official contact for
issues related to Regional Load Curtailment. Thls is the person who will be notified if
there are any changes in the Regional Curtailment Plan or meetings scheduled to
discuss it's progress, and who will be responsible for your utilitt's compliance with your
State Plan.
D€
ln the second table, enterthe information lorthe person your utility has designated as an
alternate to the primary Contact Person deslgnated in the first table. This person will be
expected to assume the duties and responsibilities of the primary Contact Person if that person
is unavailable for any reason.
NAME: Provide the otficial name of the Contaqt Person, and/or their prefened
nickname. For example, Seattle City Ught might enter'G.R. (Jeny) Garman'.
IIITE: (Optional) Provide the tiUe of the Contast Person at the utilttythey represent.
For example, 'Deputy Supt.','Power Planning Managef, or'Director, Power
Management'.
ADDRESS: Enter the address at your utihty where offtcial Regional Load Curtailment
conespondence should be sent in order to reac{r the Contact Person.
PHONE: Enter the phone number at your utilrty wlrere the Contact Person may
normally be reached during business hours. lnclude the extension number if
appropriate. lf the Contast Percon has a direct line available which would allow
bypassing the general switchboard or customer service lines, this number should be
provided.
FAX: Enterthe number at your utility (if one is available) where FAX messages can be
received by the Contact Person.
PAGER: Enter the number (if one is available) where the Contact Person rnay be
reached by pager, if necessary, after hours, on weekends and holidays, or in the event
of an emergency requiring their attention when they are not available at their regular
work phone number (provided above).
(4)LOCATION OF SERVICE AREA: A separate report must be filed for each State (within
the region) in which your utility provides service. Enter an X ln the blank to the right of
the State for which you are filing this report.
(5) TOTAL NUMBER OF CONSUMERS lN SERVICE AREA: Forthe purpose of Regional
Load Curtailment, consumers are dMded into three classiftcations based on their level
and type of consumption.
Residential @nsumers are those whose electrical consumption is utilized at their
homes, and are usually designated as'residential'consumers bytheir utilitt's rate
schedule.
General Use consumers are those who are non+esidential, but whose average
consumption during the previous year was less than or equal to 5 Megawatts per hour
(< or =43,800 MWh total annual consumption). Average consumption is typically
calculated by dividing total annual consumption (MWh) by the number of hours in a
year (8,760).
>7
Malor Use consumers are those who utilized over 5 average Megawatts during the
previous year (>43,800 MWh totalannual consumption).
MONTHLY BILLING CYCLE: Enter the total number of consumers ln each
classification who receive thelr bllls on a monthly cycle. These customers will
usually receive 12 electic bills per year.
BI-MONTHLY BILLING CYCLE: Enter the total number of consumers in each
classffication who receive their bills every other month (60 day billing cycle).
These consumers will usually receive 6 electric bills per year.
SEASONAL BILLING CYCI-E: Enter the total number of consumers in each
classification who receive their bills seasonally. These customers will usually
receive 2 electric bills per year.
(6) QUESTIONS: The Regional Load Curtailment Plan allours utilities to determine whether
or not to include consumera with etimated base period data in their audit samples (see
Sections V!.A.(4XbX1)G) and Vl.A.(s)(c) of the Regional Curtailment Plan). A
consume/s Base Period data might have to be estimated if they have been at their
cunent residence or business less than one year. The utility must decide whether their
system of estimating consumption is accurate enough to wanant including these
consumers in audit samples.
YES: Enter an X in this field if the utility includes gny consumers with estimated
Base Period data in their Residential and General Use audit samples.
NO: Enter a X in this field only if your utility excludes all consumers with
estimated data from these samples.
utilities are expected to weather adjust (normalize) their system loads as reported on
Part ll of the Report Form for comparison to actual loads. The consumption levels for
each consumer class are also expected to be weather adJusted (normalized), but lf
doing so is extremely difficult for a utility, the State may allow them to report actual
consumption, rather that weather adjusted consumption.
YES: Enter an X in this fidd if the consumer data reported under'Consumption
Levels'on Part ll of the Regional l.Xility Curtailment Report Form will be weather
adjusted (normalized).
NO: Enter an X in this field if the consumer data reported under'Consumption
Levels'on Part ll of the Regional l.Xility Curtailment Report Form will not be
weather adjusted (normalized).
(71 AUTHORIZED UTILITY EXEMPTIONS FROM THE STATE PLAN: lf your util'rty has
been exempted by the State lrom any part of the Plan, you must indicate what these
exemptions are.
Weather Adiustino (Normalizing): Enter an X in the field to the right of the
related question if you have been exempted from weather adjusting data.
D-8
otheg: Place an X in the field to the right of 'Othef if you have been granted
any other exception(s). lf you place an X in this field, you must specify the
nature of your exemption(s). Attacfi an additional explanation page if necessary
lf there were any unforeseen clrcumstances that prevented your utility from fully
complying with the State Plan, you must lndicate (on an attached explanation
page) what the circumstanos were, s,hich portion(s) of the Plan you were
unable to comply with, how long these circumstances are expected to continue,
and your strategyfor resolMng the problem (if appropriate). !f it is expected that
these same circumstances will continue to prevent you from fully complying for
more than one month, you must applyfor a utility exemption. Examples of
unforeseen circumstances include a strike of clericalworkers or meter readers, a
crash of the customer information system computer, a maior disruption such as
earthquake or volcanic eruption, etc.
PART Il: MONTHLY INFORMATION
Consumer classifications (Residential, General Use, and Major Use) are the same on this
section as on the Original Filing lnformation section (see item 5 above).
(1) NAME OF UTILITY: Enter your compant's official narne, or the name by which your
utility is commonly known in the reglon. For example, 'Public LXility District of Grant
Countf may be also be entered as'Grant County PUD'. 'Puget Sound Power & Light'
may also be entered as'Puget Powef or'PSP&L'.
(21 DATE OF REPORT: Enter the date that you are filling out this report, or the date that
you complete the report if it takes more than one day.
(3) PERSON FILING: Enterthe name of the person who is entering the data on the report
for your utility. This information is provided primarilyforthe benefit of the Contact
Person, who will be informed lf there are any problems with the data on the form. lf the
Contact Person will be entering the data personally, they should entertheir own name.
(4)REPORTING PERIOD: Enter the month, day, and year that the reporting period begins
and ends. Normally, the reporting period willbe one month long, and will be specified
by the tXility Coordinator. When entering the date, use the format mm/dd/yy (for
example: November 7, 1991 would be entered as 11/0791).
(5) STAGE (1€): Enter the Stage of Regional Load Cuftailment that has been declared by
the State Contact for your state. This will be either 1,2,3,4, or 5.
(6) PERCENTAGE LEVEL: Enterthe percentage level of curtailment that has been
ordered by the States for each consumer dass. lf the Curtailment Stage is 1, 2, or 3,
the percentage Ievel wil! be the same for all three consumer classes. lf the Curtailment
Stage is 4 or 5, the percentage level may be different for each consumer class.
D-9
(71 LOADS DURING REPORTING PERIOD: The primary purpose of the information in this
table is to provide comparisons of the amount of curtailment achieved on the utility's
system as a whole (rather than by indivldual @nsumers) relative to the proJected loads
and to the Base Period of the previous year. All figures entered in this table should
represent cumulative MWhs forthe reporting period. The figures entered must
represent the portion of system load that is subJect to curtailment under the Region
Load Curtailment Plan, and must exclude all (inpluding firm) power sales outside of the
region or between utilities within the reglon. ACruAL bads should be metered loads
without weather adjustment. WEATHER AATUSTED loads have been normalized to
reflect fluctuations caused by unusual weather. Each utility may have thelr own
formula(s) for weather adjusting load, based upon thelr past experien@, and the
formulas rnay vary for different types of consumers, depending on their weather
sensitivity.
TOTAL SYSTEM LOAD: Enterthe regionalfirm energy load on your utility's
system. For utilities with loads outside the region, the total firm energy load
must be adjusted to reflect onlythose loads served within the region affected by
the Regional Curtailment Plan. LJtilities that are BPA Purchasers are also
required to supply this figure by Section 11(b) of the Power Sales Contract. This
figure should not include firm power sales to other utilities within the region,
since the energy will be considered a resource on the receiving utilitt's system.
LOAD FORECAST GEFORE CURTAILMEND: Enter the most recent
estimated regional firm energy load for your utility, as projected prior to the
beginning of the reporting period. For utilities with loads outside the region, the
estimated firm energy load must be adjusted to reflect only those loads served
within the region affected by the Regional Curtailment Plan. Utilities that are
BPA Purchasers are also required to supply this figure by Section 11(b) of the
Power Sales Contract. This figure should not include firm power sales to other
utilities within the region, since the energy will be considered a resource on the
receMng utility's system.
BASE PERIOD LOAD: Enterthe regional firm energy load on your utilitt's
system during the Base Period that conesponds with the reporting period. This
figure should exclude firm power sales within the region, and out-of-region sales.
The Base Period is typically the same period of time as the reporting period, but
of the previous year.
(8) WEATHER ADJUSTED CONSUMPTION LEVElli: The primary purpose of the
information in this table is to provide a comparison of energy use by consumers during
the reporting period as compared to the Base Period. This indicates how each
consumer class (as opposed to individualconsumers) is complyrng, overall, with the
Stateordered level of curtailment. lt is anticipated that the overall cudailment level
achieved by each consumer class may be less than the level ordered by the State, due
to exemptions and adjustments. By weather adjusting the figures, fluctuations caused
by unusual weather are eliminated. Enter the total consumption during the indicated
period (in cumulative MWhs) for each consumer class.
Dl0
!F THE STATE ORDERED CURTATLMENT tS VOLUNTARY (STAGES 1 OR 2) DURTNG THE
REPORTING PERIOD, THE REST OF THE FIELDS ON THE FORM MAY BE LEFT BI-ANK.
THE FOLLOWING INFORMATION REI.ATES TO MANDATORY CURTAILJTIENT ONLY.
(9) COMPLIANCE: Numbers provided in this table will be compared by the database
program to the total number ol cronsumers in the service area (provided on Part l:
Original Filing lnformation) to calculate percentages, and provide cumulative totals.
NUMBER OF CONSUMERS lN SAMPLE: During mandatory curtailment
stages, utilities are required to audit (by random sample) a minimum of 1% of
their Residentialconsumers, S% of their General Use consumers, and 100% of
their Maior Use consumers. Enterthe number of consumers in the sample (by
classification) audited by your utility during the reporting period. The
consumption levels audited will be from the previous billing cycle.
NUMBER WITH ESTIMATED BASE DATA: Enter the number of consumers in
each sample for which there was no valid Base Period data, and for which
Target Consumption l-evels had to be estimated. The majority of these wil!
probably be those @nsumers wlro have been at their cunent service location for
less than one year. Utilities have the option of excluding consumers with
estimated Base Period data lrom their random samples, and replacing them with
consumers for which they are able to derive actual Base Period data. lf your
utility excludes consumers with estimated Base Period data, enter a'0'and
indicate'No'on the related question in Part l: Original Filing lnformation (item 6).
NUMBER (WITH CONSUMPTIONI MEETING OR BELOW TARGET: EnteT the
number ol consumers in each sample whose consumption levelwas less than
or equalto theirtarget consumption level. These consumersl are in full
compliance wtth the State-ordered curtailment level.
NUMBER (WITH CONSUMPTIONI GREATER THAN TARGET BUT LESS
THAN THRESHOLD: Enter the number of consumerc in each classification
whose consumption level was greater than their target level, but within the
threshold band. These @nsumers are not subject to penalties, but should be
advised that they are not complying with the Stateordered curtailment level.
NUMBER (WITH CONSUMPTIOM GREATER THAN THRESHOLD: Enter the
number of consumers in each dassification whose consumption was overtheir
target by more than the threshold level. These @nsumers will be subject to
penalties for lailure to comply wtth the Stateordered curtailment level.
(10) NUMBER OF CONSUMERS WITH PENALTIES ASSESSED: The information in this
table is intended to provide an indication of the effectiveness of the applied penalties.
Cumulative totals will be calculated by the database. lf a large number of consumers
continue to exceed their target and threshold levels in spite of these penalties, it would
indicate that the penalties are not an adequate detenent. Enter the number of
consumers by classification who were assessed penalties at each of the indicated
levels lor lailure to comply with the State-ordered curtailment level.
D-11
(11) EXEMPTIONS/ATNUSTMENTS: The first table on thls page represents the number of
consumers whose exemption and/or adjustment applications were processed during
the reporting period.
The second table indicates the estimated load in MWhs represented bythe exemptions
and/or adjustments that were granted. For customers who are billed other than
monthly, the monthly estimate may be derived by dMding a bi<nonthly meter reading ln
half (for example), or any other means the utility leels is appropriate.
EXEMPTIONS APPLIED FOR: Enter the nurnber of exemption applications that
were received by your utility during the reporting period.
EXEMPTIONS GRANTED BY UTILIW: Enter the number of exemption
applications that your utility granted during this reporting period in the first table.
ln the second table, calculate the total load of exempted consumers (converted
from kWh to M\lttlh) during the previous reporting period. This figure should be
the sum of the meter readings for each @nsumer who was exempted by the
utility from mandatory ctrtailment.
EXEMPTIONS DENIED BY UTILITY: Enter the number of exemption
applications that your utility denled during the reporting period.
EXEMPTIONS PENDING REVIEUII BY UTILITY: Enter the total number of
exemption applications that your utility was unable to process during the
reporting period. These may include applications carried over from previous
reporting periods. This figure provides an indication of a utility's ability to meet
the administrative task of processing the number of exemption applications
received in atimely manner.
ADJUSTMENTS APPLIED FOR: Enter the number of adjustment applications
that were received by your utility during the reporting period.
ADJUSTMENTS GRANTED BY UTILITY: Enter the number of adjustment
applications that your utility granted during this reporting period in the first table.
ln the second table, calculate the total load (converted from kWh to MWh)
exempted from mandatory curtailment due to adjustments that were applicable
during the previous reporting period. This figure should be the sum of the Ioad
adjustment for each of the consumers who were granted a specific adjustment
by the utility for that particular reporting period.
ADJUSTMENTS DENIED BY UTILIW: Enterthe number of adjustment
applications that your utility denied during the reporting period.
ADJUSTMENTS PENDING REVIEW BY UTILITY: ENtErthE tOtAI NUMbET Of
adjustment applications that your utility was unable to process during the
reporting period. These may include applications carried over from previous
Dl2
reporting periods. This figure provides an indication of a utilitfs ability to meet
the administrative task of processing the number of adjustment applications
received in a timely manner.
EXEMPTIONS GRANTED BY STATE: ln the first table, enter the number of
exemption applications that were previously denied by your utility, but that were
appealed to, and granted by, the State. The State will provide notice to the
appropriate utility anytime they decide to grant an exemption appeal.
ln the second table, calculate the total load during the previous reporting period
(converted from kWh to MWh) of consumers whose exemption appeals have
been granted by the State. This figure should be the sum of the meter readings
for each @nsumer who was exempted by the State lrom mandatory curtailment.
ATUUSTMENTS GRANTED BY THE STATE: ln the first table, enter the number
of adjustment applications that were appealed to, and granted by, the State
during this reporting period.
ln the second table, calculate the total load (converted from kWh to MWh)
exempted from mandatory curtailment due to adjustment appeals granted by
the State that were applicable during the previous reporting period. This figure
should be the sum of the load adjustment for each of the @nsumers who were
granted a speciftc adjustment by the State for that particular reporting period.
(12) DOLIAR AMOUNT OF PENALTY SURCHARGES ASSESSED: Enter the total amount
of penalty surcharges assessed during the reporting period.
(13) DISBURSEMENT OF SURCHARGE REVENUES:
E: Enter an X in the !es'field if any revenues from penalty surcharges were
expended during the reporting period. lf an X is entered in the !es'field, you
must indicate how the funds were utilized in one or more of the fields below.
Enter an X in any field that applies. lf an X is entered in the 'othef field, you
must attadr an additional page explaining how the funds were utilized.
[Q: Enter an X in the 'no'field if there was no expenditure of penalty surcharge
revenues during the reporting period.
D-13
ADDRESSES FOR FILING REGIONAL UTILITY CURTAILMENT REPORT FORMS
UTILITY COORDINATOR:OREGON STATE:
Northwest Power Pool
Attn: Rich Nassief
26 S.W. Salmon Street, Suite 400
Portland, OR 97204
PHONE: (50s) a6a-2se7FAX: (503) +6a-2319
WASHINGTON STATE:
Washington State Energy Office
Attn: Mark Anderson
809 Legion Way, SE FA-11
Olympia, WA 98504-1211
PHONE: (206) 95&2012FAX: (206) 75&2397
IDAHO STATE:
ldaho Public Utilities Commission
Attn: Keith Hessing
State House Mail
Boise, !D 8ti7026000
PHONE: [phone]FAX: (2o8) 3s+-3762
Oregon Public Utility Commission
Attn: Roger Colbum
3@ Labor & lndustries Bldg.
Salem, OR 97310-0335
PHONE: (503) 378€894FAX: (5os) 37+7752
MONTANA STATE:
State of Montana - Energy Division
Attn: John Goroski
Dept. of Natural Resources & Conseruatio
1520 East 6th
Helena, MT 59620-2301
PHONE: @oQ eaa4762FAX: @oQ aa-6721
D-14
APPENDIX E
CONTACT INFORMATION REGARDING
THE UTILITY COORDINATOR. STATE CONTACTS. AND UTILITY CONTACTS
Contact
lAlternatel
UTILIW COORDINATOR
Rhh Nassiof, Drcc{or
fGlenn Traegerl
STATE CONTACTS
ldaho State
lGith Hesslng
[Don Olasonl
Montana State
Ahn Davis, Bureau Chle{
[Van Jamicon, Admlnistrator]
Oreqon State
Ron Eachus, Commigdon Chairman
[Wlfiam Warcn, Adminisilrator
olthe Energy Dvidonl
Washlnoton State
Amy Bell, Dircctor
[Dan Dodds]
UTILITY CONTACTS
Bonnevllle Power Ad mlnlstratlon
Mark W. Maher, Director
Divislon of Power Supply
[Richard L Hainee Chi€f
Power&hedule Brarrchl
Chelan Countv PUD
Wllard Fields, Dir. Porver Operations
[Jack Clarke, Dir. Customer SeMcal
Address
lAlt.Addressl
NorthwsC Power Pool
26 SW. Salmon S:beet Sulte {x)
Podhnd, OR 97204
ldaho Pub[c Uti[lies Commlssion
State House Mail
Boisa, lD 83702€0@
Montana Dept of Naturd Resources
& Conservailon - Energy DMslon
1520 E. Sbdh Avenue
Helena. MT 5962G2301
Oregon Publc W[ty Commission
300 l,abor & Indusdes Building
Salem, OR 97310-OgB5
Washlngton State Energy Office
809 Legion Way, S.E. FA-l1
Olympia, WA 9850+1211
Bonneville Power Administration
P.O. Box 491
Vancouver, WA 98666{491
P.O. Box 1231
Wenatchee, WA 98807-1231
Phone
IAlt. Phonel
503-{6/t-28O7
[503-{6+280Sl
208334-0348
I208€34{3491
46,-444-6756,
[.r06411€7s41
503€78661'l
Iso3€78.6osr}]
20s95e2001
[20s95e21421
206€9G2103
[206-6eG210Ol
509€63€121
[so9€63€r211
Far
IAlt. Faxl
503-46+2819
n&33/,-3762
4A6444-6721
fi3^s73-7752
re75&23,97
206€9G2920
5@€6+2879
Gontact
lAltematel
Cowlltz Countv PUD
J. lcon Srnith. Gerpral Manager
[Vem L Eaton, Commerdal Managerl
Douolas Countv PUD
Eldon E. landin, Manager
[Henry G. Lu&an, Porver Operations
Supedntendentl
Euoene Water & Electrlc Board
Garry W. Kunkel Die Elect& Divlslon
[Vaughn W. Scales, Manager of
Power Besourcesl
Grant Gountv PUD
Don [ong, Dlrector Power Managenrnt
[Bob Oberg, Porver Operatons ol
Coordinatorl
ldaho Power Gompanv
Jim Miller, Manager Power Operations
[Jim Collngwood, Creneral Managsr,
Power Operalionsl
Montana Power Gompanv
Robed L Miller. Execulive Assistant
Transrnlsslon & Power Management
ffhomas J. Woring, Manager
Power Supplyl
PaclflGom
Dennis P. Steinberg, Vice PreCdent
Power Sysfiemo and Development
[Bdan D. Siickels,
Asst. Vie Pleident Power Syetemsl
Pend Orellle PUD
Jim Scheel, Mgr. ol Operations
[Dick Arkills, Dpctor of
Hydro Operations & Power Supplyl
Address
[Alt.Addressl
960 Gomnprce Avenue
Bo(3007
Longvbw,WA S8632
I tSt Valhy Mall Parhrvay
E. Wenatchee, WA 98802
P.O. Bol( t0l,f8
Eugene, OR 97f40
P.O. Box878
Ephrat+ WA 98823
P.O. BoxTO
Bolee, lD 83707
,O East Broadway
Brrte, MT 59701
7(X) N.E Muthomah - Suib 1600
Pordand. OR 97232
[920 S.W.6th Ave, Room 1314 PSB
Portland, OR 972041
Box Canyon Dam
P.O. Box 5{7
lone, WA 99139
50$731-2157 5tr,-73l-n27
[503-46+56re][503464-s0261
Phone
tAlt. Phonel
re5n-7512
[2065/7-75Gll
so9€84-7191
503484€7Al
[503.484€7671
50+754-5055
Isos754-50571
20838$2865
[208A8]242s1
406!494-8193
e><L 4276
1406-72.3-5421
elo 46241
w9-442.5232
Iso9-{42.32321
tAlt. FaxI
206\tz-7559
509€84-0553
50$341-r889
50975+5012
20&3686905
4064944282
Fax
E-2
509-442.3168
Contact
lAlternatel
Portland General Electrlc
Stero Conkln, Manager Porver Operalions
[Gene Cubbage, Managerl
lndusfiial Marketing
Address
[Alt.Addressl
121 S.W. Salmon Street
Podland, Oregon
P.O. Box97G?{
Bellevue. WA 9800+9734
10l5Third Avenrc
Seattle, WA 98104-1198
[1 I 11 Third Avenue, Suite 420
Seattle, WA 981011
P.O. Bo,( tlOT
Ewret, WA 98206
P.O. Box l1(X)7
Tacoma. WA 98411
Phone
lAlt. Phonel
w&724o
I509464€6071
206-452€137
[20G482€1451
20e3864500
I206€8&4s3OI
re25€€?97
l2f6-25€42771
20G5998295
[20ss9+82941
50&23G7395
50&32&3735
[50]32&37z15l
5@.482€O4O
[509482€0801
Fax
tAlt. FaxI
5@-4eLrc75
[sos46+702e1
206-462-3800
[20c462€1751
204386-4555
20&258€!'05
20G38$9628
50$23G7397
503€26€141
Puqet Sound Power & Lloht
Rich Larckhart V.P.. Powor Phnning
lElill Galne!, Managpr,
Resource Operationel
Seattle Cltv Lloht
G. R. Garman, Deputy Supedntendent
Power Resourcos Brarrch
[R. A. Nelson, Drector, Porver Mgmt
Power Resourcec Brarchl
Snohomlsh Countv PUD
Coe Hubhinson,
Director of Rateo & Porver Supply
[Barbara Pedersen,
Dircctor of Power Supplyl
Tacoma Cltv Lloht
Stew Klein, Porver Manager
[George Wh]tsner, Asst Porver Managerl
U. S. Goros of Enolneers
Nick Dodge, Chlef. Waier Management Div. P. O. Box 2870
[Russ George, Chief, Reservcir Control Ctr.] Portland, OR 9720&2870
Washlnoton Water Power
U. S. Bureau of Reclamatlon
Bob Barbo, Spe<JalAssil. to Reg. Dir
for Columtia River Operation
[Jim Fodrea Columtria River
Technical Coordinatorl
W. L Bryan, V. P., Poner Supply
[R. L Stono, Manager, Power Supply]
9l't N.E. Avenue- Room 125
Portland. OR 97232
P,O.Box37t?
Spokane, WA 99220
E-3
*9.4€,24272
APPENDIX F
STATE STATUTES AND STATE AGENCIES
This Plan is consistent wtth applicable State law in each of the affected Statea. The statutes
that apply are cited below, along with the State agencies responsible for administration of the
law and other relevant utility business.
A. Washington
(1) Applicable Lawo The Emergency Powers Act of 1977, BCVV 43.21G;o State Energy ffice enabling legislation - RCW 43.21F, specifically
RCW 4r'.21F.045(1).
State Authorities. Washington State Energy Office (administers curtailment);. Washington Transportation and Ljtilities Commission (approves rates,
tenders State orders to lOUs).
B. Oreqon
(1) Applicable law. Oregon Revised Statutes 757.710, ORS 757.720, and ORS 757.730.
State Authoritieso Oregon Public Utilrty Commission (approves rates; administers
curtailment);. Oregon Department of Energy (consults with the PUC in approving
curtailment plans).
c.ldaho
(1)Applicable Law. ldaho Code Sections 61401, 61404, 61405, 61406, 61€01, 61€02, 61-
507, 61-508, 61€20, 61€21, 61€31 through 61-537, 61612, 61€14, 61-
625, and all provisions of ChapterT ol Title 21 of the ldaho Code.
State Authoritieso ldaho Public tJtilities Commission.
D. Montana
(1) Applicable Law. Montana Code Annotate - Energy Supply Emergency Powers Act, 904-
301 through 904€19, MCA;. Adminlstrative Rules of Montana - Electricity Shortages, ARM 14.8.201
through 14.8.230.
State Authoritieso Montana Govemor (administers curtailment);o Montana Department of Natural Resources and Conservation (compiles
and evaluates shortage data, provides analysis and recommendations to
Govemor);. Montana Public Seruice Commission (sets rates).
(2)
(2)
(2)
(2t
APPENDIX G
ANNUAL UPDATES TO THE PI-AN
c:\lc\plan\abclg.doc
CONDENSED VERSION
REGIONAL CURTAILMENT PLAN
FOR EI-ECTRIC ENERGY
within the States of Washlnqton. Oreqon. ldaho. and Montana
SECTIONS I AND II. PURPOSE AND OVERVIEW OF THE REGIONAL CURTATLMENT PI-AN
This Plan identifies the process by whic*r the States of Washington, Oregon, ldaho, and
Montana would initiate and implement regional load curtailment. lncluded in the Plan are
detailed procedures to be followed during a protracted regional electrical energy shortage to
ensure uniform treatment of all regionalconsumers. The Plan ls not intended to be activated
for relatively short-term emergencies such as those caused by extremely cold weather orthe
temporary loss of a major transmission line, even if individual States take action to alleviate the
problem.
The goal of this Plan is to accomplish curtailment while treating consumers fairly and equitably,
minimizing adverse impacts from curtailment, complying wtth existing State laws and
regulations, and providing for smooth, efficient, and effective curtailment administration. This
Plan serves as a guideline or blueprint for eacfi of the lour Pacific Northwest States to use in
developing their individual State curtailment plans.
SECTION III. DEFINITIONS
The following definitions apply to terms used in this Regional Curtailment Plan and in individual
State plans. lf the first letter(s) of the term are shown ln parentheses, the term may appear in
either upper case or lower case throughout the Plan.
A. Base Billing Perlod. One of the billing periods comprising the Base Year. Billing Periods
are established by the utility and are normally either monthly or bimonthly. Base Billing
Period data are weather-normalized before being used to calculate the amount of
curtailment achieved.
B. Base Year. Normally, the l2month pedod lmmediately preceding imposition of State-
initiated load curtailment. lf energy use during that period is atypicd, States may select a
ditferent 1 2-month period.
C. Critical Load Consumer. A consumer that supplies essential services relating to public
health, public safety, or energy production.
D. Curtailment. Load reduction, inepective of the means by which that reduction is
achieved.
E. Curtailment Taroet. The maximum amount of energy that a consumer may use and stlll
remain in compliance with the State curtailment order; the Curtailment Target is figured
individually for each @nsumer by Base Elilling Period.
F. Excess Power Consumptlon. The lower of the lollowing two values for loads subject to
penalty: (1) the difference between a consume/s astual (or metered) consumption level
during a billing period and the Curtailment Target, or (2) the difference between the
consume/s weather-normalized energy use during a billing period and the Cudailment
Target.
G. Extra-Reolona!. Any load, resour@, or entity located outside of the region as defined in
section 3.(14) of P.L. 95-501, the NW PowerAct.
H. General Use Consumer. Any non-residential consumer who does not qualify as a Major
Use Consumer.
l. lmplementation Record. The collestion of significant notes, memos, conespondence,
and other material generated for each curtailment, whether such documents are formal or
informal in nature. The utility Coordinator ls responsible for maintaining the
I mplementation Record.
J. Maior Use Consumer. A consumer who has purchased over 5 average annual
megawatts (4t1,800 tvtwh) during the Base Year.
K. Non-Reolonal. Any load, resource, or entity located outside of the region as defined in
this Plan.
L Elgtr This Regional Curtailment Plan.
M. Reqlon. The State of Washington, Oregon, ldaho, and those portions of Montana that
are west of the Continental Divide and/orwlthln the control area of the Montana Power
Company.
N. Reolonal Electric Enerqy Curtallment fuialysls Model (REECAM). A computer
program used by the l.Jtility Coordinator and other lnterested parties to evaluate the status
of the regional electric power system and analyze the need lor region-wide curtailment.
O. Reglonal [oad. The load placed by ultimate @nsumers within the region on their
repective utility suppliers; the load sublect to curtailment under this Plan.
P. State. Any of the four Pacific Northwest States: Washington, Oregon, ldaho, and
Montana.
O. State Contact(s). lndividuals who representtheir respective States in connection with
cudailment issues.
-2-
R. State-lnltlated. Actions taken by the States to implement their individual State load
curtailment plans.
S. Threshold Consumotlon level. The modmum amount of energy that a consumer can
use during mandatory load curtallment without being subJect to penalties under this Plan.
T. Utlllty Contact(el. lndividuals who represent thelr respective utilities in connestion with
curtailment issues.
U. UtlllU Coordinator. The Director of the Northwest Power Pool
V. UtlllU Curtallment Reports. Report(s) summarizing curtailment data; such reports are to
be submitted monthly by utilities to their respestive States and the tXility Coordinator.
W. Weather-Normallzatlon. The procedure that utilities use to reflect the impact of weather
on utility load levels. Some utilities referto this process as \rueather-adjustment.'
SECTION IV. CURTAILMENT STAGES
State cuftailment directives applyto all Regional Loads. Underthe Plan, curtailment is
requested or ordered as a percentage of historical, weather- normalized (Base Billing Period)
electric energy consumption. Although the curtailment stages are generally associated with
increasing deficits, the stages are not necessarily implemented in a sequential manner; the
Plan is flexible so as to allow States to move from one curtailment stage to another as required
to adapt to rapid and dramatic changes ln the energy supply situation.
The live curtailment stages are:
Staoe # Nature Curtallment %Tvpe of Curtallment
Stage 1
Stage 2
Stage 3
Stage 4
Voluntary
Voluntary
Mandatory
Mandatory
No Specffied %
5%+
5% - 15%
15%
15% +
15% +
% Associated
with Stage 4
+ additional
curtailment
Stage 5 Mandatory
Uniform among all regional consumers
Uniform among all regional consumers
Uniform among all regional consumers
Residential Consumerc
GeneralUse Consumers
Maior Use Consumers
Continued Consumer Curtailment
plus utility Action, including
Plant Closures and possible
BlackOuts
-&,
SECTION V. INITIATION OF REGIONAL LOAD CURTAILIT,IENT
Using REECAM (desoibed in Appendix A of the Plan) and other analyticaltools, the utility
Coordinator shall monitor the region's energy situation and notify State and Utility Contacts
when it appears that a protracted energy shortage could be developing. The State Contacts, in
consultation with the utility Coordinator, Utility Contacts, and other interested parties, will
analyze the results of REECAM to determlne if reglonal load curtailment is required. lf they
agree on the need, they will settle on the appropriate stage and level (percentage reduction),
consult wtth others wtthin their respective States using briefing materials prepared bythe l.Xility
Coordinator, and then again coordinate with each other. To the extent changes in the original
recommendation are lndicated as a result of such intra-State consultations, the State Contacts
willwork togetherto reach a new consensus. The State Contacts willthen begin developing
situation-specific curtailment implementation procedures. The States will initiate region-wide
load curtailment by notifying the public, the l.Jtility Coordinator, and all utilities operating within
their respective borders that load curtailment ls ln effect.
SECTION VI. ADMIN ISTRATION OF STATE.IN ITIATED CU RTATLN,I ENT
A. Utilitv Activities
(1) Overview
(a) Abllltv of Utllitles to Complv wlth Plan Hequlrements. utilities will
conform to the requirements of their respective State plans to the extent
possible. tJtilities may petition their States for exemption from specific
requirements of their State plan.
(b)Stage-by€tage UtlllU Admlnistratlve Obllgatlons. Upon notice that
their respective States have called for regional load cudailment, the
region's utilities shall immediately begin complying with the directives of
their State plan(s). All requirements for lower level stages continue to
apply to higher level stages. Throughout the curtailment period, utilities
will provide consumers with as much useful information as they
reasonably can. The requirements specified below represent the
minimum astions that each utility must take to remain in compliance with
the Plan.
Stage 1. LJtilities must begin (or continue if they have already begun)
providing curtailment lnformation to their consumefti. Both the nature
of the lnformation and the means by which they convey it to
consumers (media communications, bill stuffers, etc.) are left to the
utility. l.Jtilities shallalso assist States, as appropriate, in briefing the
media about the shortage.
a
a Stage 2. ln Stage 2, utilities must: (a) notify their consumers of the
percentage level of State-initiated voluntary curtailment; (b) provide
curtailment tips to consumers; (c) answer consumer questions about
curtailment; (d) provide curtailment reports to the States and the
4-
l.Xility Coordinator; and (e) provide more detailed lnformation to the
media than provided in Stage 1.
Stage 3. ln Stage 3, utilities must: (a) notify their consumers of the
percentage level of State-ordered mandatory curtailment; (b)
calculate weather-normalized Base Billing Period data and
Curtailment Targets for all @nsumers who will be audited ln the
cunent billing period; (c) provide Curtailment Targets to all
consumers who request such data lorthelr own a@ounts; (d)
provide audited @nsumers with information about how to apply for
exemption and adjustment ol Base Year data; (e) process requests
for exemption and Base Year data adjustments from those
consumers selected lor audit who would otheruise be subject to
penalties; and (0 implement the penafties aspect of the Plan.
Stage 4. ln Stage 4, utilities must notifytheir consumers of any
applicable changes in Stateinitiated rnandatory curtailment.
Stage 5. ln Stage 5, utilities must collaborate with the States to
develop and implement the most effective methods for securing the
required load curtailment.
el Suqoested Curtallment Actlons.
l.Jtilities shall disseminate inlormation to consumers regarding actions they can
take to reduce their electric energy consumption. The States and utilities will
work togetherto develop this material. The re@mmendations will be based on
the actions described in Appendix C of the Plan, 'Curtailment Measures.'
Utilities will be responsible lortailoring this curtailment information to their
service areas, adding utility-specific information, printing, and disseminating the
material to their @nsumerc.
(3) Base Year Data and Curtaltment Taroets.
(a)ldentification of the Base Year, Each time the Plan is activated, the
States will identify the applicable Base Year. Once established, the Base
Year for a shortage will remain unchanged throughout the curtailment
period. Normally, the Base Year ls the 12-month period immediately
preceding initiation of load curtailment underthis Plan. Base Year and
Base Billing Period data shall be weather-normalized using the utility's
standard procedures. The States may choose an altemative Base Year if
they decide that the data for the 12+nonth period preceding load
curtailment is atypical and its use would result in an inequitable allocation
of curtailment among the region's cgnsumers.
(b) Estimatlng Base Billino Perlod Data for Consumers for Whom No
Base Bllllno Perlod Data Exlsts. Base Billing Period data must be
obtained or developed for any consumer who is audited under this Plan.
Utilities have the option of excluding residential and General Use
a
a
a
-s,
(4)
Consumers without actual Base Billing Period data from the random
sample ol audited @nsumers. LJtilities must estimate the Base Billing
Period data for any audited consumer for whom actual data does not
exist or is lound to be inaccurate.
(c) Communlcatlno Curtallment Tarqet lnformatlon to Consumers.
During mandatory curtallment, utllities are required to provide
retrospective, cunent bllling period, and forthcomlng billlng period
Curtailment Target lnformation to any @nsumer wlro so requests.
l.Jtilities are also required to provide retrospective Curtailment Target
inlormation to any audited consumer who will be lssued a waming or
penalty. At their option, utilitie may provide Cuftailment Target
information to other @nsumers or @nsumer classes as well.
Auditino Consumerc for Compllance with State Orders for Mandatory load
Curtailment. Each month, utilities must audit at least one percent of residential
users, five percent of General Use Consumers, and 100% of their Major Use
Consumers (including those Maior Use Consumers with estimated Base Billing
Period data) plus any consumers penalized in the previous billing period. The
number ol consumers exempted or orcluded lrom audit does not afiest the
sample size.
New samples shal! be draum eacfr month. Consumers penalized underthis Plan
shall continue to be audited until their energy use falls below the Threshold
Consumption Level. Once their energy use falls below that level, they will be
audited again only if selected by random sample.
Unless a utility is auditing 10095 of its residential users and General Use
Consumers, all such @nsum€ra selected lor audit shall be chosen on a random
sample basis, except that the following consumers are to be excluded:
(a) consumers granted an exemption underthis Plan; and (b) consumers with
an estimated power bill in the cunent billing period. LJtilities may also choose to
exclude @nsumers wtth estimated Base Billing Period data, assuming the
States do not require their inclusion in the pool of consumers subject to audit.
(5) Penaltles for Non€ompllance.
(a) Nature of Penaltles. The Plan identiftes penalties for non+xempted
consumers wtro failto comply with State orders for mandatory
curtailment. The penalties underthis Plan are structured as follows:
Violatlon t Penalty
First B-monthly Molation
Second Bimonthly Violation
Third Bimonthly Molation
Fourth Bimonthly Molation
100 per kWh of excess use
2OO per kWh of excess use
400 per kWh of excess use
1 Day Disconnestion +
409 per kWh of excess use
+
The penatty for violators who are billed every two months will
escalate on every power bill in which they are subject to penalty.
Consumers billed on a monthly basis will be assessed the same
penalty on two successive occasions before incuning the next
higher level penalty. During any continuous period of curtailment,
assessed penalties remain'on the record'forthe purposes of
administration of subsequent penalties, even if there has been an
intervening period of 'compliance.'
Utilities are expected to adhere to their standard disconnect criteria and
procedures whenever disoonnecting cunsumers in accordance with this
Plan. Heatth, safety, and wdfare considerations are to be taken into
account, and consumers must pay normaldisconnect and reconnect
charges.
(b) Calculatlon of Flnanclal Penaltles. Financial penalties will be
calculated by multiplying the consume/s Excess Power Consumption
each billing pedod bythe appropriate penalty levelidentifted above.
G)Threshold Coneumptlon Lcvel. The Threshold Consumption
Level assigned to each consumer class ls ldentified in the table
below. lf the required load reductions are not occuning during a
curtailment period, the States may change the percentage
relationship of the Threshold Consumption Levelto the
Curtailment Target so as to effect better compliance wtth the
curtailment order.
*
Fifth Bi-monthly Molation
Sixth and All Subsequent
Violations
2Day Disconnection +
4OO per kWh of excess use
Penalties are determined by
the State. Civi! penalties or
other conective actions would
be possibilities.
Threshold
Consumptlon Level
1096 above Curtailment Target
1096 above Curtailment Target
2% above Curtailment Target
Type of
Consumer
Residential Consumers
General Use Consumers
Malor Use Consumers
@ Excess Power Consumption Calculatlon. Penalties are not
assessed if a consume/s load (either actual load or weather-
normalized load) is equalto, or less than, the Threshold
Consumption tevel. Excess Power Consumption is the lower of
the following two values for each sampled load subject to
penalty: (g) (Astual Load) minus (Curtailment Target) or (!)
(Weather-Normal ized Load) m i n us (Cu rtail ment Target).
-7-
(c) Assessment of Penaltles.
0_) Penaltlee vs Wamlnos. Consumers will be assessed penalties
only if they have Ercess Power Consumption and if they are to be
penalized based on the utilitfs penalty assessment procedures
descdbed bdow. Any sampled consumer who is not penalized
and whose use exceeds the Curtailment Target wtll receive a
waming.
@ Penalty Assessment Procedures. LJtilities sampling at the
mandated minimum percentages for each sector as specified in
this Plan [1%-6%-10096] (or as otherwise specffied by the States
and reflected in the lmplementatlon Record) shall asisess
penalties on all @nsumers wtth Excess Power Consumption.
LJtilities sampling a higher percentage of consumers than required
under the Plan may choose among the following penalty
assessment options:
g) Assess penalties on allsampled @nsumers with Excess
Power Consumption; (this methodology must be used for
Maior Use Consumers even if the utility chooses option
(b), below, for its other consumer sectors); or
O Develop a ratio of the minimum percentage sample size to
the actual percentage sampled for the residential and/or
General Use consumer sestorc. Multiply the resulting
pecentages by the total number of violators in each
respective @nsumer sector to determine the minimum
number ol penalties that must be assessed in each sector.
Calculate the percentage violation for each lndMdual
consum€r that has been sampled (Excess Power
Consumption divided by Curtailment Target) and apply
penalties to the \rorst offenders'In the overall sample
based on their percentage'Excess Power Consumption.'
Also penalize all@nsumers wlro were penalized in the
previous billing period and wtro still have Excess Power
Consumption.
(g) Treatment of DSls. Penalties applicable to BPAs direct-seMce
lndustrial customers will be assessed by the States based on
billing data provided by BPA.
(d) Bllllno Coneumerc for Penaltlee. utilities may describe the penalty on
the power bill as'State-mandated' and shall include any State-provided
material desctibing the penalty aspect of the Plan as a bill stuffer in the
bills of penalized consumers. The States will consider printing this
material on State letterhead so as to reinforce the publiCs understanding
that penalties are due to a violation of State mandate. LJtilities shall note
-&
that failure to pay penalties will result in seMce disconnection ln
accordance with standard disconnect criteria and procedures.
(e) Treatment of Penaltlee Pendlnq Adluetment/Exemptlon
Determlnatlons. Consumers who have applied for adjustment of Base
Billing Period data and/or exemption from mandatory curtailment may
request a stay of enforcement of the penalty aspec't of the Plan pending
a final decision regarding its request. Any consumer who has been
granted such a stay shall be sublec't to retroactive penalties as applicable
lf the request is ultimately denied.
Use of Funds Collected under the Penalty Provlslons of the Plan.
Funds collested under State-ordered penalty provisions of this Plan shall
be set aside in a separate account. The ultimate disposition of these
funds will be determined bythe appropriate State commisslon ln the
case of investor-owned utilities and by the goveming bodies of publicly-
owned utilities.
(6) tncentlves. Whenever curtailment is in effect, individual utilities are enoouraged
to implement creative lncentive programs to motivate @nsumers to provide
additional load reductions relative to their Curtailment Targets.
(7) Exemptlons and Adluetments.
(a) Consumer Appllcatlon for Exemptlon/Adiustment. utilities are
responsible for inlorming their @nsumers how to apply for exemption
lrom Plan requirements or adjustment of Base Billing Period data.
Utilities may elect to process oremptions and adjustments onlyfor
zudited consumers. Consumers seeking an exemption or adjustment
shall apply first to their utility and then, if dissatisfied with that outcome,
to their respective State. The State will not consider any consume/s
appeal unless it has first been processed by the consume/s utility.
(b) Grantlno Consumer Requests for Exemptlon from Mandatory
Curtallment. No automatic consumer exemptions will be granted under
mandatory State-initiated load crrtailment. Exempted consumeni should
be told that exemption may not protect them from Stage 5 black-outs.
Crltlcal load Consumers. Crttical Load Consumers may be
exempted once they have demonstrated to their utility that they
have eliminated all non-essentialenergy use and are using any
reliable, cost-effective back-up energy resour@s in load.
0
a
Other Consumerc. Exemptions for consumers not qualifying as
Critical Load Consumerc under this Plan will be evaluated based
on whether curtailment would result in unreasonable exposure to
health or safety hazards, seriously impair the welfare ol the
affected @nsumer, cause extreme economic hardship relative to
the amount of energy saved, or produce counterproductive
results.
a
-9
(c) Utillty Record-Keeplnq Relatlve to Consumer Exemptlons. tJtilities
shall make their records regarding exemption determinations available to
their respective States upon request.
(d) Utlllty Exemptlon lrom State Plan Requlrements. utilities may appeal
to their rapective States, requesting an exemption from any aspect of
their State plan. Their petition tor exemption should identifythe specific
requirements lrom whlcfi they wish to be orempted, the reason(s) behind
their request, and altemative actions that they can reasonably take in lieu
of such requirements.
(8)Measurement of the Amount of Curtallment Achleved and Determlnatlon of
Compllance. At alltime dudng State-initiated regional load curtailment, utilities
shall provide their respective States and the Utilily Coordinator with
consumption and savings data on a monthly basis in the form specified in
Appendix D of the Plan. To the ortent that circumstances at the time of actual
load curtailment diqtate the need lor additional data or more frequent data
submittal, the States shallso inform the utilities and the utilities shall use best
efforts to comply with the State request.
(9) SpeclalArranoements.
(a) Use of Consumer-Oruned Generatlon Facllltlee. The States'
mandatory cuilailment orders apply only to electric energy purchased
from a utility: all consurners are required to reduce their electric energy
purchases from their utility by the required percentage. However,
consistent wtth their respective utilitt's needs for safety and system
protection, @nsumerc having their own generation facilities or access to
electricity from non.utility power sources may use energyfrom those
other sour@s to supplement their curtailed power purchases from their
electric utility.
(b) Curtallment Schedullno. During periods of mandatory curtailment, a
@nsumer is obligated to provide the requisite amount of curtailment
within each billing peliod. Within that period, and subject to equipment
limitations and utility rules on load fluctuations, @nsumers are free to
schedule their curtailment so as to minimize the economic cost,
hardship, or inconvenience they experience as a result ol the mandatory
curtailment requirement.
Case-by4ase Arranqements. LJtilities may choose to work creatively
with lndividual consumers to secure additional curtailments as
appropriate.
B. State Activitles
(1) Provldlno Curtallment lnformation to Utilitles. States shall provide utilities
with information regarding cudailment adrninistration and work with utilities to
(c)
-1G
(2)
(3)
develop consumer curtailment tips for consumers. (See Plan Appendix B,
Types of Curtailment lnformation'and Appendlx C, 'Curtailment Measures.')
Proceeelno Utllitv Requeste for Exemptlon and Second Level Consumer
Appeals for Adiustmente and/or Exemptlons. The States shall process utility
requests lor exemption from Plan requirements and @nsumer requests for
either exemption or adjustment of Base Year data in cas€s where the consumer
is appealing its utilitfs determlnation. The States shall keep interested parties
apprised of the status of appeals{nprocess.
Perlodlc Reaeseesment of Mmlnlstratlve Declelons and Malntenance of the
lmplementatlon Record. Together, the States will review the appropriateness
and continued applicability of lmplementation decislons on a monthly basis, or
as othemise indicated. Signtftcant decisions shall be recorded in the
lmplementation Hecord. The typ6 of matters that will be addressed in the
periodic reviews and wtrich may be reflected in materials that will become part of
the lmplementation Record include:
Achievements and Obfectlves. Analysis of the amount of curtailment
actually achieved based on the data provided ln the t tility Curtailment
Reports and a review of the most recent HEECAM results;
Curtallment Staoe and Lovel. ldentffication of the applicable
curtailment stage and level; also, any identified procedures for changing
the applicable curtailment stage and/or level;
Public lnformatlon. The general agreement among the States as to
howto disseminate the curtailment message: tenor of messages, dates
of announcements, specifics as to utilized media, etc.;
Base Year Consumptlon. The Base Year to be used for measuring
curtailment impaqts;
Procedural Matters.
(a) Development of additional administrative procedures as required;(b) Assessment of the need, il *y, for making changes to the Plan to
secure increased compliance with the curtailment directives;(c) Eliscussion of implementation problems and proposed solutions
thereto; and(d) Evaluation of the appropriateness of the materials being made
available to utilities and provided by utilitie to the States, and a
determination as to whether changes are required;
Curtallment Recorde. The specific requirements on utilities and States
regarding curtailment records (what needs to be recorded, how that
lnformation willbe stored, tlfro can a@ess it...); and
a
a
a
a
a
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a Return to Normal Operatlons. The generalagreement among the
States relative to announcing an end to regional load curtailment and
resuming normal utility operations.
C. Return to Normal Operations. Once the shortage is alleviated, the States and utilities
must bring closure to the curtailment process and effect a retum to normal operations.
The States will detailthe process for utilities to follow. The nature of the actions to be
taken will be influenced bythe applicable stage of curtailment. At a minimum, the
following types of activities need to occur: (1) The public must be informed that
cuftailment is no longer required; (2) Curtailment activities must officially cease as of the
date that curtailment orders are lifted bythe States. The States will provide utilities with
guidelines to bring closure to curtailment activities such as: exemptions and appeals,
penalty assessments, curtailment incentives (if any), and curtailment reports; and (3) State
authorities willtake whatever action is required to rescind any State orders for mandatory
load curtailment.
SECTION VII. UTILITY LIABILITY AND FINANCIAL RELIEF
State law in each of the four Pacific Northwest States provides for waivers of, or exemptions
from, liability in the case of utilities enforcing mandatory load curtailment ordered bythe State.
lndividual @nsumer data will be treated as proprietary ln accordance with standard utility
practices and State law (identffied in Plan Appendix F). lf State law prohibits utilities from
releasing consumer aeount information to the State, @nsumers seeking exemptions and/or
adjustments shall expressly authorize such exchange. utilities may seek financial relief for the
extraordinary costs of curtailment using established channels, including utility rate case
procedures and BPA power sales contract provisions.
sEcTtoN vilt. ANNUAL REV|EW, POST€URTATLMENT EVALUATTON, AND UPDATE
OF THE REGIONAL CURTAILMENT PI-AN
At least once a year and after any curtailment, the tJtility Coordinator will convene a meeting of
allfour State Contacts and interested utilitia forthe purpose of reviewing and updating the
Plan and associated Appendices. Upon completion of the review, neoessary changes will be
made, a list of those changes prepared, and a revised plan issued. Changes will be noted in
Appendix G.
SECTIONS IX AND X. APPENDICES AND REI.ATED CURTAILTT'IENT INFORMATION
The following appendices are included in the Plan: (A) Regional Electric Energy Curtailment
Analysis Model; (B) Curtailment lnformation; (C) Curtailment Measures; (D) l.Xility Curtailment
Reports; (E) Contact lnformation Regarding the utility Coordinator, State Contacts, and Utility
Contacts; (F) State Statutes Citations and State Agencies; and (G) Annual Updates to the Plan
The following supplemental material is available under separate cover: (A) lndividual State
Plans and Summary of the Differences among the State Plans; (B) utility Plans; and (C) State
Statutes (copies of the actual statutory language).
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