28856.doc

BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION

in the matter of THE APPLICATION OF IDAHO POWER COMPANY TO UPDATE ITS EMERGENCY CURTAILMENT PROCEDURES UNDER TARIFF RULE J. )
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CASE NO. IPC-E-01-20

ORDER NO.  28856

On June 5, 2001, Idaho Power Company filed its Electric Load Management Procedures (the “Curtailment Procedures”) for the curtailment and interruption of electric service pursuant to the Company’s Rule J Tariff. The Curtailment Procedures are guidelines employed by the Company to temporarily interrupt electric service to its customers during emergencies and power shortages. The Curtailment Procedures are intended to provide equitable guidelines for the curtailment of power while minimizing adverse impacts to customers and maintaining overall system reliability.
On August 3, 2001, the Commission issued a Notice of Modified Procedure seeking public comment on Idaho Power’s Curtailment Procedures. Comments were to be filed no later than August 31, 2001. Only the Commission Staff commented.
THE APPLICATION
Idaho Power serves customers in Idaho and eastern Oregon. Its generation, transmission and distribution facilities (commonly referred to as components of its system) serve customers in Idaho and Oregon. In addition, the Company’s coal-fired thermal generating resources are located in Wyoming, Nevada, and Oregon. Idaho Power’s system is interconnected with other utility systems in the western United States in a regional system that is commonly referred to as the “western grid.” The western grid includes two Canadian Provinces, 11 western states, and a portion of Mexico. The Western Systems Coordinating Council (WSCC) administers operating criteria to maintain the integrity and reliability of the western grid.
Although the Company’s operations are designed to provide a constant and reliable source of electrical supply, situations may arise that require Idaho Power to interrupt service to its customers. For purposes of Rule J, these situations include unforeseen outages and fluctuations caused by: 1) weather, animals, and equipment failure on the Company’s generation, transmission and/or distribution systems; 2) an inability to procure sufficient quantities of energy from its own generation or from the wholesale market; and 3) constraints in the transmission system that inhibit Idaho Power from importing or distributing energy into or within its system.
Curtailment of the Company’s services may occur in one of two general circumstances. First, curtailment may be caused by unforeseen events with little or no warning. For example, lightning strike or equipment failures may cause protection equipment within the Company’s electric system to automatically “trip” to protect the system from damage (or further damage) and to maintain reliability of the unaffected portion of the system. Second, curtailment may result from circumstances that gradually develop over time or occur in a foreseeable manner. Examples of this second type of curtailment include power shortages caused by extended cold weather or extremely low streamflow conditions.
Relationship to Other Plans
The Company’s Rule J Curtailment Procedures are also related to Idaho Power’s participation in the “Regional Load Curtailment Plan” (RLCP) and the “Northwest Energy Emergency Plan” (NEEP). The RLCP addresses shortage of regional electric supply, i.e., when the Northwest suffers a prolonged energy shortage due to drought or other fuel shortage conditions. Under this RLCP, the states of Idaho, Montana, Oregon and Washington implement voluntary and mandatory load curtailments. The intent of the RLCP is to have customers reduce their loads so that rotational power outages (rolling blackouts) can be avoided.
The NEEP contains procedures for: 1) identifying potential Northwest energy shortages; 2) issuing appropriate public alerts; 3) coordinating communication efforts; and 4) taking actions to reduce shortages. The NEEP was developed by the Pacific Northwest Utilities Coordinating Council to increase the region’s ability to avoid power emergencies or longer-term adequacy problems by promoting regional coordination, cooperation and communications. The NEEP is aimed at promoting actions in advance to avoid potential short-term capacity emergencies and longer-term adequacy problems in the Northwest Power Pool area. Among other things, the NEEP provides criteria for communicating emergency warnings and energy adequacy problems to the utilities, state and federal agencies, public officials, and the public. Once a regional warning has been issued, load reduction measures include: halting discretionary exports of power; adjusting planned outages for the maintenance of generation or transmission facilities; operating generating resources to full operational capabilities; exploring options to increase transmission capability; and curtailing supplies to customers via existing contract provisions or purchasing load reductions from customers.
Three Stages
Idaho Power’s Rule J Curtailment Procedures contemplate three stages consistent with the Northwest Energy Emergency Plan’s (NERC) definition or criteria that escalate in relationship to the severity of the emergency. The applicability of Stage 1 and Stage 2 alerts will depend upon the circumstance(s) that are causing or contributing to the power emergency. For example, situations that require immediate attention may necessitate moving immediately to a Stage 3 power emergency.
Idaho Power’s system is required to operate in a “balanced” condition. In other words, at any given time the generating resources of the Company must be sufficient to meet the demand or load caused by customer usage. The WSCC requires Idaho Power (and all utilities) to maintain a 5% reserve capacity for hydroelectric generating resources and a 7% reserve for thermal (coal and gas-fired) generating resources. Under its Curtailment Procedures, the Company will declare a Stage 1 power alert when it foresees or is experiencing conditions where it cannot sustain spinning and non-spinning reserves of at least 5% hydro and 7% thermal. Before declaring a Stage 1 alert, the Company will: 1) bring online all available generation; 2) purchase necessary additional generation from sellers or the Northwest Power Pool; 3) exercise its right to curtail power delivery to interruptible customers and non-firm wholesale energy loads; and 4) seek voluntary curtailments.
When declaring a Stage 1 alert, the Company will issue public warnings requesting that all customers reduce energy usage on a voluntary basis. Idaho Power will also notify the WSCC regional coordinator and the State Communications Center.
In the event that Idaho Power cannot maintain its 5% and 7% reserves, then the Company will declare a Stage 2 alert. Additional actions for Stage 2 alert include seeking emergency power assistance from neighboring utilities and increasing efforts to conserve or reduce load.
At such time as the Company’s reserves fall below 2.5% for hydro and 3.5% for thermal, then the Stage 3 power emergency will be declared. Stage 3 emergencies require the Company to curtail load. As previously mentioned, Stage 3 power emergency may also occur if there is a disturbance or event which requires immediate action to maintain system reliability. In such extreme emergencies, the Company will take automatic action to balance load in order to avert a system blackout. If the automated load shedding mechanisms are not sufficient to maintain system reliability, the Company will initiate load shedding in the form of rotational outages.
C. Rotational Outages
Idaho Power’s service areas are divided into five regions. The regions are: Payette (Payette, Eastern Oregon, McCall areas); Canyon (Canyon County area); Capital (the Boise area); Southern (the Twin Falls area); and Eastern (the Pocatello area). If rotational outages are required, the Company’s control center will determine the amount of load to be curtailed in each region. The necessary curtailments will be allocated on a pro-rata basis according to load in each of the five regions. Idaho Power’s Control Center will inform each Regional Dispatch Center of its curtailment obligation. In the event that the problem is confined to a local area within a region, the regional team will decide how much load to curtail.
It is the Company’s intent to implement rotational outages in a fair and equitable manner, while maintaining system reliability. Each regional team will use its best judgment based upon their knowledge of the system and customers to make decisions regarding which distribution circuits to curtail and the curtailment sequence. When implementing rotational outages, distribution circuits in each of the five regions will be curtailed. Outages are expected to last one to two hours. Customer requirements, cold load pick-up, crew availability, etc. will determine the outage duration. When possible, advanced notification will be provided to facilitate preparations and to minimize the effect on customers.
When rotational outages become necessary, information will be disseminated through voice mail messages, e-mail, the Company Internet site, and public announcements. Depending on the events that precipitate the various stages, the Northwest Security Coordinator, the Idaho State Communications Center, the U.S. Department of Energy, the Idaho Public Utilities Commission and large customers will be notified. The State Communications Center will then provide notification to the Bureau of Disaster Services, County/City 911 Centers, Fire Departments, Sheriff’s Departments, Police Departments, Red Cross and various public officials.
THE COMMENTS
As previously mentioned, the only comments filed in this matter were submitted by the Commission Staff. After reviewing the Company’s curtailment procedures, Staff found that the procedures are workable and are in the best interest of the public health, safety and welfare.
Specifically addressing the rotational outages, Staff noted that the procedures utilize both load reduction and increased generation measures to mitigate the need for curtailments. Staff did find that spreading the rotational outages evenly across Idaho Power’s five regions was equitable and fair. “The planned curtailment of 1-2 hours appropriately balance the need to safeguard system reliability while minimizing adverse impacts to customers.” Staff Comments at 7.
Staff also recommended that the Company revise the language in its tariff Rule J so that the tariff more accurately reflects the procedures to be followed when curtailments are employed. Staff recommended and the Company agreed that the tariff should be amended to clarify when the Regional Load Curtailment Plan (RLCP) is being implemented.
DISCUSSION
Idaho Code § 61-531 requires all electric corporations to maintain a plan or procedures for the curtailment of electric or gas consumption during emergencies. Idaho Code § 61-532 requires these procedures be submitted and reviewed by the Commission. In reviewing the procedures or guidelines, the Commission is to consider: (1) consistency of the procedures with the public health, safety and welfare; (2) the technical feasibility of implementing the procedures; (3) and the effectiveness with which the procedures minimize the impact of any curtailment on customers. Id.
Having reviewed the Company’s curtailment guidelines and the Staff comments, we find it is appropriate to approve Idaho Power’s updated curtailment procedures. We believe that the procedures adequately plan for both foreseen and unforeseen events. We further find that the curtailment procedures, in relationship to the other regional plans, are workable and serve the public health, safety and welfare.
In those instances where rotational outages are necessary, we believe that the curtailment procedures will minimize impacts upon customers while maintaining overall system reliability. We believe it is appropriate for the Company to employ both load reductions and obtain increased generation (from internal resources or regional resources) to mitigate the need for curtailments.
We also adopt the Staff’s recommendation that the Company should submit revised tariff sheets to clearly identify when the RLCP is being implemented. The tariff revision should clearly identify the procedures contained in the curtailment plan. We anticipate that the Staff and the Company will work together to ensure that the tariff revisions are accomplished in a timely manner.
O R D E R
IT IS HEREBY ORDERED that Idaho Power’s Electric Load Management Procedures are approved.
IT IS FURTHER ORDERED that the Company revise its Rule J tariff to include those revisions identified in the body of this Order.
THIS IS A FINAL ORDER. Any person interested in this Order (or in issues finally decided by this Order) or in interlocutory Orders previously issued in this Case No. IPC-E-01-20 may petition for reconsideration within twenty-one (21) days of the service date of this Order with regard to any matter decided in this order or in interlocutory Orders previously issued in this Case No. IPC-E-01-20. Within seven (7) days after any person has petitioned for reconsideration, any other person may cross-petition for reconsideration. See Idaho Code § 61626.

DONE by Order of the Idaho Public Utilities Commission at Boise, Idaho this
day of September 2001.

PAUL KJELLANDER, PRESIDENT

MARSHA H. SMITH, COMMISSIONER

DENNIS S. HANSEN, COMMISSIONER

ATTEST:

Jean D. Jewell
Commission Secretary

vld/O:IPC-E-01-20_dh2

ORDER NO. 28856 1

Office of the Secretary
Service Date
September 17, 2001