09072001.doc

DECISION MEMORANDUM

TO: COMMISSIONER KJELLANDER
COMMISSIONER SMITH
COMMISSIONER HANSEN
JEAN JEWELL
RON LAW
LOU ANN WESTERFIELD
BILL EASTLAKE
LYNN ANDERSON
RANDY LOBB
DAVE SCHUNKE
BEV BARKER
TONYA CLARK
GENE FADNESS
WORKING FILE
FROM:
DATE:
SEPTEMBER 7, 2001 RE: UPDATING IDAHO POWER COMPANY’S CURTAILMENT PLAN,
CASE NO. IPC-E-01-20

On June 5, 2001, Idaho Power filed its proposed Electric Load Management Plan (the “Curtailment Plan”) for the curtailment and interruption of electric service pursuant to the Company’s Rule J Tariffs. The Curtailment Plan outlines the procedures employed by the Company to temporarily interrupt electric service to its customers during emergencies and power shortages. The Curtailment Plan is intended to provide equitable procedures 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 comment on Idaho Power’s Curtailment Plan. 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.
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 could 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 hydro conditions.
A. Three Stages
Idaho Power’s Rule J Curtailment Plan contemplates 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.
Without getting too technical, 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 Plan, 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.
B. 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 plan, Staff recommended approval of the Company’s updated Curtailment Plan. The Staff found that the plan is workable and is in the best interest of the public health, safety and welfare.
Specifically addressing the rotational outages, the Staff noted that the plan employs 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.
Because the Company did not file a revised tariff sheet for Rule J, Staff recommended that the Company revise the language in its tariff Rule J “so that the tariff more accurately reflects the new procedures.” Id. In particular, Tariff Sheet J-1 merely refers to load curtailment procedures. See attached Tariff p. J-1. Staff recommended and the Company agreed that the tariff should be amended to reference both the Regional Curtailment Plan and the Northwest Emergency Plan.
COMMISSION DECISION
Does the Commission find Idaho Power’s updated Curtailment Plan is reasonable and appropriate?
Should the Company be instructed to revise its tariff to address those concerns raised the Commission Staff?
Anything else?

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

DECISION MEMORANDUM 1