20210511Application.pdf

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Lead Gounsel
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Attachments
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May 1 1,2021
VIA ELECTRONIC FILING
Jan Noriyuki, Secretary
ldaho Public Utilities Commission
11331 W. Chinden Blvd., Bldg. 8,
Suite 201-A(83714)
PO Box 83720
Boise, ldaho 83720-007 4
Case No. IPC-E-21-13
Idaho Power Company's Application for Approval of its Load Curtailment
and lnterruption Plan
Dear Ms. Noriyuki:
Attached for electronic filing is ldaho Power Company's Application in the above
entitled matter. Also enclosed are Ms. Kathleen Anderson's direct testimony in the above-
referenced matter, as well as the proposed updates to the Company's tariff schedule Rule
J, Continuity, Curtailment and lnterruption of Electric Service.
lf you have any questions about the attached documents, please do not hesitate to
contact me.
Very truly yours,
Re
X*!-fl^1.t,-*,
Lisa D. Nordstrom
LISA D. NORDSTROM (lSB No. 5733)
ldaho Power Company
1221West ldaho Street (83702)
P.O. Box 70
Boise, ldaho 83707
Telephone: [phone]
Facsimile: [phone]
lnordstrom@ idahooower.com
Attorney for ldaho Power Company
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
!N THE MATTER OF IDAHO POWER
COMPANY'S APPLICATION FOR
APPROVAL OF ITS LOAD
CURTAILMENT AND INTERRUPTION
PLAN
CASE NO. |PC-E-21-13
APPLICATION
ldaho Power ("ldaho Power" or "Company") hereby respectfully applies to the
ldaho Public Utilities Commission ("Commission") pursuant to ldaho Code SS 61-531
and -532 for approval of its 2021 Load Curtailment and lnterruption Plan, as we!! as to
update its Electric Service Rule J Continuity, Curtailment, and lntenuption of Electric
Service. ln support of this Application, ldaho Power represents as follows:
I. BACKGROUND
1. ldaho Power is a public utility supplying retail electric service to more than
590,000 customers in southern ldaho and eastern Oregon. ldaho Power is subject to the
jurisdiction of this Commission in ldaho and to the jurisdiction of the Public Utility
Commission of Oregon. ldaho Power is also subject to the jurisdiction of the Federal
Energy Regulatory Commission, which has delegated authority to the North American
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)
)
APPLICATION - 1
Electric Reliability Corporation ("NERC") to develop and enforce mandatory bulk-power
system planning and reliability standards throughout North America.
2. /daho Code S 61-531. Plan for Curtailment of Electric or Gas Consumption
compelled the ldaho Public Utilities Gommission to require al! suppliers of electric power
and energy to file with the Commission a plan for the curtailment of electric or gas
consumption during an emergency period.
3. Resiona! Plan. ln November 1993 the Commission orderedt the electric
service suppliers in the state of ldaho to adopt provisions relating to electric service
curtailment during periods of prolonged energy shortages such as drought, severe
operational constraints, or moratoriums. The provisions were based on the Regional
Curtailment Plan for Electric Energy ("Regiona! Plan"), a plan designed to serve as a
guideline for states to use in developing their own individual curtailment plans to deal
effectively with long-term energy shortages and to promote curtailment uniformity among
the four Pacific Northwest states of Oregon, Washington, ldaho and Montana.2
4. Modified Reoional Plan. Using the Regional Plan as a working guideline,
the Commission ultimately required one modification to the Regional Plan concerning
non-compliance penalties; this "Modified Regional Plan" became the State Curtailment
Plan.3 Idaho Power and numerous other utilities adopted the Modified Regional Plan in
individual plans that were collectively approved in Commission Order No. 25634.4 The
State Curtailment Plan has not been modified since its adoption in 1994.
1 ln re Adoption of a State-Wde Curtailrnent Plan for Hectic Energy, Case No. GNR-E-93-02, Order No. 25259
(November 24,1gg3).
2 The Regional Plan has not been subsequently updated.
3 Case No. GNR-E-93-02, Order No. 25634 (July 11, 1994).
4 ld.
APPLICATION - 2
5. ln addition to incorporating the Modified Regiona! Plan, the Company's
existing tariff Rule J "Continuity, Curtailment and Interruption of Electric Service" ("Rule
J") provides additional information about the regulatory and legal framework surrounding
curtailment and interruption of electric service during periods other than long-term energy
shortages.
6. 2001 Rule J Uodate. ln June 2001, the Company filed an update to its
"Electric Load Management Rule J Procedures" ("Rule J Procedures") docketed as Case
No. IPC-E-01-20. The Rule J Procedures are high-level guidelines employed by the
Company to temporarily interupt electric service to its customers during emergencies
and power shortages and are intended to provide equitable guidelines for the curtailment
of power while minimizing adverse impacts to customers and maintaining overall system
reliability. These procedures were approved by the Commission in 20015 and an update
was Iodged with the Commission in July 2002.
7. Load Manaoement Procedures. The Company also maintains a more
detailed operationa! procedure manua!, the Load Management Procedures ("LMP"),
which serves as interna! procedural manual for dealing with both short-term and long-
term emergencies, interruption and curtailment. The LMP is regularly reviewed and
updated by the Company's operations departments.
8. A thorough review of the Modified Regional Plan and the Rule J Procedures
revealed thatthey no longer represented howthe Company addresses curtailment. Since
the Company filed its Modified Regional Plan in 1993, and Rule J Procedures in 2001
and 2002, changes in technology, industry practices, and generation capacity, Ioad
5 ln the Matter of the Application of ldaho Power Company to Update lts Emergency Curtailment
Procedures under Tariff Rule J, Case No. IPC-E-01-20, Order No. 28856 (September 17,2001).
APPLICATION - 3
shedding demand response programs, and resource availability have served to make
them outdated. !n particular, processes related to regional coordination have been
updated by the industry reliability organizations such as NERC and the Western Energy
Coordinating Council ('WECC"). The WECC is a Regional Entity given authority by the
NERC to monitor and enforces compliance with reliability standards. The Company also
supports Regional Reliability Coordinatorso, who monitorvoltages, frequencies, and other
reliability indices. Moreover, the existing Modified Regional Plan is only for long-term
energy shortages and doesn't address short-term supply emergencies resulting from loss
of major generation or transmission equipment, regiona! operating standards, or weather
extremes. The currently filed Rule J Procedures similarly need an update to reflect how
the Company addresses curtailment.
9. Consequently, the Company requests the Commission approve its 2021
"Load Curtailment and Interruption Plan" ('LCIP'), its current practices and procedures
related to curtailment of both a short-term and prolonged nature. The LCIP applies to
emergencies declared by state entitiesT, and when directed by the NERC or the WECC
(under which authority is delegated to a Regional Reliability Coordinator) and by ldaho
Power at its own discretion. The Plan is operational throughout the year and is a tool for
safe, efficient load reduction during high stress system events.
6 ldaho Power's current Reliability Coordinator is the RC West, operated by the California lndependent
System Operator.
7 Pursuant to ldaho Code $ 61-533 the Commission "shall have the authority to declare an emergency,
with or without notice, upon finding that an inadequacy or insufficiency of electric power and energy, or
natural or manufactured gas threatens the health, safety and welfare of the citizens of this state." /daho
Code $ 61-534 states that the Commission "shall have authority to require all suppliers of electric power
and energy, or natural or manufactured gas, except agencies of the federal government, to curtail service
in accordance with the curtailment plans on file with and approved by the commission." ln the Company's
Oregon jurisdiction, such emergency authority is provided to the governor of Oregon under Oregon
Revised Statutes 176.7 50-176.820.
APPLICATION - 4
10. Further, to enhance transparency and to provide customers with relevant
information regarding the Company's procedures related to load curtailment and
intenuption, the Company is proposing to incorporate lhe 2021 LCIP into its Rule J tariff.
!!. MODIFICATIONS TO THE EXISTING CURTAILMENT PLAN AND
PROGEDURES
11. The Company's 2021 LCIP, which is included as Attachment 1 to this
Application and is incorporated into the proposed Rule J included as Attachment2 to this
Application, combines elements of the Modified Regional Plan originally filed in 1993 and
the Rule J Procedures last filed in 2002. Previously, the Modified Regional Plan has
addressed only long-term regional eneryy shortages, while the Rule J Procedures cover
short-term emergencies. ln contrast, the 2021 LCIP contains both short- and long-term
operational activities the Company can initiate during emergencies to minimize adverse
impacts to customers and restore system stability. The 2021 LCIP addresses the
Company's operational approach to:
. Initiation of Load Curtailment,
o Automatic, Remote and Manual Actions,
. Curtailment Stages
. lnterruptible Loads,
. Block Rotation,
o Emergency Load Shed Groups, and
. Return to Service.
12. The 2021 LCIP incorporates the Company's current approach to dealing
with Curtailment and lnterruptions, including adding provisions for load reduction with
APPLICATION - 5
demand response and emergency shed groups, clarifying the types of entities that can
order ldaho Power to initiate load curtailment, and identifying a broader range of events
that could precipitate Ioad curtailment activities.
13. Curtailment Resources. The 2021 LCIP incorporates additional
curtailment sources, including interuptible customer load programs such as demand
response programs, which if available are the first resources to be used when immediate
system stabilization is required. The demand response program provisions of Schedules
23,81, and 82, including but not limited to operating hours, notification requirements, and
incentive payments will not apply for any time period that the Company utilizes a load
control device installed under the programs to interrupt a participating customer's load for
an electric system emergency.
14. The 2021 LCIP also uses block rotation, the rotational curtailments used in
scheduled combinations until the necessary load curtailment is achieved. Block rctation
provides equitable treatment to affected customers as the combination of blocks curtailed is
dependent on the day of the week and time of day the curtailment is required. The 2021
LCIP also includes emergency load shed grcups, predetermined localized groups that are
utilized for situations where load reductions might be required for specific high load areas.
15. Events Precipitatino Curtailment. Events that may trigger load curtailment,
either upon notice from state agencies, the Regional Reliability Coordinator, or at the
discretion of the Company, include but are not limited to:
o Fire, flood, drought, winds, generation failures, lack of sufficient generating
capacity, eq u i pment fail u res, governmenta I autho rity;
APPLICAT]ON - 6
. Actions taken to protect the performance, integrity, reliability or stability of the
Company's electrical system or any electrical system to which it is
interconnected, which actions may occur automatically or manually;
o Actions taken by the Company that in its sole judgment are necessary or prudent
for the safety of people and/or equipment;
. Cyber-attacks or software failure of any part of the Company's generation,
transmission, and/or distribution system protection and/or control systems.
16. ln addition to the content modifications described above, the Company
proposes incorporating the LCIP within its Rule J Tariff on file with the Commission. The
proposed Rule J incorporating the 2021 LCIP is attached as Attachment 2 to this Application.
III. COMMUNICATONS
17. Communications and service of pleadings, with reference to this
Application should be sent to the following:
Lisa D. Nordstrom
Lead Counsel
ldaho Power Company
P.O. Box 70
Boise, ldaho 83707
lno rd strom@ ida hopower. co m
Connie Aschenbrenner
Rate Design Senior Manager
ldaho Power Company
P.O. Box 70
Boise, ldaho 83701
caschen bre n ne r@ id a ho powe r. co m
ldaho Power Dockets: [e-mail]
IV. MODIFIED PROCEDURE
18. ldaho Power believes that it would be appropriate to process this case by
means of Modified Procedure (i.e., by written submissions rather than by hearing) in
accordance with the provisions of RP 201-210 et. Seq. However, if the Commission
prefers another procedure for processing, the Company has pre-filed the direct testimony
of Company witness Kathleen Anderson.
APPLICATION - 7
V. REQUEST FOR RELIEF
19. For the reasons set forth above and in the supporting testimony, ldaho
Power respectfully requests that the Commission: (1) issue an order authorizing that
this matter be processed by Modified Procedure; and (2) approve the Company's 2021
LCIP and modifications to Electric Service Rule J to incorporate the updated LCIP.
DATED at Boise, ldaho, this 11h day of May 2021.
X* !.Z(^l-t"-*,
LISA D. NORDSTROM
Attomey for ldaho Power Company
APPLICATION - 8
BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
GASE NO. IPG-E-21-13
IDAHO POWER COMPANY
APPLIGATION
ATTACHMENT 1
ldaho Power
Load Curtailment and
lnterruption Plan
Discussion
Idaho Power will comply with all state and federal mandates to curtail the
electric energy used by its customers to prevent an electrical system collapse.
Events that may trigger load curtailment<ither upon notice from
government authorities, the regional reliability coordinator (RC), or at the
discretion of the company-include, but are not limited to, the following:
Fire, flood, drought, winds, generation failures, lack of sufficient
generating capacity, equipment failures, governmental authority
Actions taken to protect the performance, integrity, reliability,
or stability ofthe company's electrical systern or any electrical syston to
which it is interconnected, which may occur automatically ormanually
Actions taken by the company that in its sole judgment are necessary or
prudent for the safety of people and/or equipment
Cyber-attacks or software failure of any part of the company's
generation, transmission, and/or distribution system protection and/or
control systems
Load curtailment can last for a short time or could last for hours<r even days.
Plan
Automatic, Remote, and Manual Actions
Automatic actions occur through the operation of programmed protective
equipment installed on the company's electrical systan, including, without
limitation, equipment such as automatic relays, generator controls, circuit
breakers, and switches. This protection equipment is preset to operate
under certain prescribed conditions that, in the sole judgment of the
company, threaten system performance, integrity, reliability, or stability.
Where Supervisory Control and Data Acquisition (SCADA) equipment is
installed, Idaho Power will remotely control switches, circuit breakers, relays,
voltage regulators, or other equipment. In areas where no SCADA equipment is
installed, actions are performed manually by on-site field personnel.
a
a
o
Load Serving Operations Page 1
2021 Load Curtailment and lnterruption Plan ldaho Power
If actions are undertaken, to the extent permitted by the operating characteristics
of the electrical system, the company will perform such actions so interruption,
curtailment, or fluctuation of service to customers will be accomplished
sequentially-unless it is necessary in the sole judgment of the company, or if
required by the regional RC to vary the sequence to protect system performance,
integnty, reliability, or stability.
C u rta i I m ent a n d I nterru ptio n
Curtailment and/or intemrption of electric service can occur at any time for a
multitude of situations. When these situations arise, Idaho Power intends to take
appropriate actions to mitigate the situation for reliability while maintaining
service continuity to as many customers as practical. Depending on the nature of
the situation, mitigation actions will range from actions that will not affect
customers to actions that curtail and/or interrupt service, impacting localized
aroas and/or the entire Idaho Power service area.
Idaho Power will promptly notiff and keep state regulatory and reliability
authorities informed of the curtailment and/or intemrption to electric service.
Rotating Outages and Ongoing Curtailment
Curtailment and/or intemrption of customer load may be necessary to maintain
the reliability of the electric system in certain situations. If Idaho Power must
curtail or intemrpt customer load for any reason, the company's intent is to
curtail the appropriate amount of load necessary to mitigate the situation. This is
accomplished by selecting the amount or percent of load reduction needed in the
Energy Managernent System (EMS) Load Shedding application. The EMS Load
Shedding application allows the operator to select the applicable localized area
or necessary portions of the company's service area to curtail the load. Load
curtailment is accomplished manually in areas that do not have SCADA
connected to the EMS.
A range of curtailment stages associated with increasing levels of energy
deficiencies has been developed, incorporating North American Electric
Reliability Corporation (NERC) standards. The circumstances necessitating a
reduction in electricity consumption in the short term will normally require
immediate emergency action to be taken. As such, there may be little or no
warning. Sudden equipment outages or loss of generation could potentially lead
directly to any curtailment stage without prior notice or progression of the stages
described in the following. These stages align with the severity of the energy
deficiency and are intended to minimize customer impact.
Page 2 Load Serving Operations
ldaho Power 2021Load Curtailment and lnterruption Plan
Table 1. Curtailment stages
Stage Nature Type of Curtailment
2
All generation resources are committed. Firm
customer load, firm transactions, and reserve
commitments are met. Concemed about
sustaining required contingency reserves.
ldaho Power is no longer able to provide
expected eneruy requirements.
ldaho Power is unable to meet minimum
contingency reserves as required by NERC
Standards.
Emergency load shed due to immediate risk
posed to electrical reliability.
o Non-firm wholesale energy sales.r Ask customers to voluntarily take conservation
measures.o lssue communications notifring employees of
the situation and asking departments to reduce
intemal utility energy use.
o Curtailment actions listed in Stage 1.o lntemrptible customer load and available
demand-response programs.o lssue communications requesting govemment
agencies implement their programs to achieve
necessary energy reductions.
o Curtailmentactions listed in Stage 1 and Stage 2. lmplement emergency load shed and block
rotation.
3
4 Applicable to all customers. May be limited to a
specific location if reliability risk is local to an
arca.
o Demand response programs, if deployed as required action under this plan, will not be
operated under the provisions of schedules 23,81, and 82. The provisions of schedules
23,81, and 82-including but not limited to, operating hours, notification requirements,
and incentive payments-rruill not apply for any time period the company utilizes a load
contro! device installed under the programs to interrupt a participating custome/s load
for an electric system emergency.
Return to Senrice
Idaho Power will to return service to all its customers when:
o It can meet its load and required operating reserves.
o The reliability of the electric system will not be jeopardized.
o RC approval has been received, if applicable.
Revision History
Review Date Revisions
05t1'U2021 Procedure was adopted.
Load Serving Operations Page 3
BEFORE THE
IDAHO PUBLIG UTILITIES COMMISSION
GASE NO. IPC-E-21-13
IDAHO POWER COMPANY
APPLICATION
ATTACHMENT 2
ldaho Power Company
l.lC No 29 No o1
First Revised Sheet No. J-1
Cancels
OrioinalSheet No. J-1P1
RULE J
CONTINUITY. CURTAILMENT AND
INTERRUPTION OF ELECTRIC
SERVICE
1. Electric Service is inherently subject to occasional interruption, suspension, curtailment,
and fluctuation. The Company wil! have no liability to its Customers or any other persons for any
interruption, suspension, curtailment, or fluctuation in service or for any loss or damage caused thereby if
such interruption, suspension, curtailment, or fluctuation results from any of the following:
a. Causes beyond the Company's reasonable contro! including, but not limited to,
fire, flood, drought, winds, acts of the elements, court orders, insurrections or riots, generation
failures, lack of sufficient generating capacity, breakdowns of or damage to facilities of the
Company or of third parties, acts of God or public enemy, strikes or other labor disputes, civil,
military or governmental authority, electrical disturbances originating on or transmitted through
electrical systems with which the Company's system is interconnected, and acts or omissions of
third parties;
b. Repair, maintenance, improvement, renewal or replacement work on the
Company's electrical system, which work in the sole judgment of the Company is necessary or
prudent; to the extent practicable work shall be done at such time as will minimize inconvenience
to the Customer and, whenever practicable, the Customer shall be given reasonable notice of
such work;
c. Actions taken by the Company, which in its sole judgment are necessary or
prudent to protect the performance, integrity, reliability or stability of the Company's electrical
system or any electrical system with which it is inter-connected, which actions may occur
automatically or manually.
2. The provisions of this rule do not affect any person's rights in tort.
3. Load curtailment and interruption canied out in compliance with an order by governmenta!
authority shal! follow the Company's plan entitled "Load Curtailment and lntenuption Plan", as outlined
below.
IDAHO
lssued per Order No.
Effective -
lssued by TDAHO POWER COMPANY
Timothy E. Tatum, Vice President, Regulatory Affairs
1221 West Idaho Street, Boise, ldaho
ldaho Power Company
I.P.U.C. No. 29. Tariff No. 101 OrioinalSheet No J-2
RULE J
CONTINUITY. CURTAILMENT AND
INTERRUPTION OF ELECTRIC
SERVICE
LOAD GURTAILMENT AND INTERRUPTION PLAN:
OVERVIEW
1. The Company will comply with all state and federa! mandates to curtail the electric
energy used by its Customers to prevent an electrical system collapse. Events that may trigger load
curtailment, either upon notice from state agencies, the Regional Reliability Coordinator, or at the
discretion of the Company, include but are not limited to:
a. Fire, flood, drought, winds, generation failures, lack of sufficient generating capacity,
equipment failures, govemmental authority,
b. Actions taken to protect the performance, integrity, reliability or stability of the
Company's electrical system or any electrical system to which it is interconnected, which
actions may occur automatically or manually,
c. Actions taken by the Company that in its sole judgment are necessary or prudent for the
safety of people and/or equipment, or
d. Cyber-attacks or software failure of any part of the Company's generation, transmission,
and/or distribution system protection and/or control systems.
2. Load curtailment can last for a short amount of time, but also could last for hours or even
days
AUTOMATIC. REMOTE AND MANUAL ACTIONS
1. Automatic actions occur through the operation of programmed protective equipment
installed on the Company's electricalsystem, including, without limitation, equipment such as automatic
relays, generator controls, circuit breakers, and switches. This protection equipment is preset to
operate under certain prescribed conditions that, in the sole judgment of the Company, threaten system
performance, i nteg rity, reliabi lity or stability.
2. \Mrere Supervisory Control and Data Acquisition (SCADA) equipment is installed, the
Company will remotely control switches, circuit breakers, relays, voltage regulators or other equipment.
ln areas where no SCADA equipment is installed, actions are performed manually by on-site field
personnel.
3. lf actions are undertaken, then to the extent permitted by the operating characteristics of
the electrical system, the Company will perform such actions so that interruption, curtailment, or
fluctuation of service to customers will be accomplished sequentially, unless it is necessary in the sole
judgment of the Company, or if required by the Regiona! Reliability Coordinator to vary said sequence
in order to protect system performance, integrity, reliability or stability.
IDAHO
Issued per Order No.
Effective -
lssued by IDAHO POWER COMPANY
Timothy E. Tatum, Vice President, Regulatory Affairs
1221 West ldaho Street, Boise, ldaho
ldaho Power Company
LP.U.C. No. 29. Tariff No. 101 Oriqinal Sheet No. J-3
RULE J
CONTINUITY. CURTAILMENT AND
SERVICE
CURTAILMENT AND ! NTERRUPTION
1. Curtailment and/or interruption of electric service can occur at any time for a multitude of
situations. \Mren these situations arise, ldaho Power intends to take appropriate actions to mitigate the
situation for reliability while maintaining service continuity to as many customers as practical.
Depending on the nature of the situation, mitigation actions will range from actions that will not affect
Customers to actions that curtail and/or interrupt service, impacting localized areas and/or the entire
ldaho Power service area.
2. ldaho Power wil! promptly notify and keep state regulatory and reliability authorities
informed of the curtailment and/or interruption to electric service.
ROTATING OUTAGES AND ONGOING CURTAILMENT
1. Curtailment and/or interruption of Customer load may be necessary to maintain the
reliability of the electric system in certain situations. !n the event ldaho Power must curtai! or interrupt
Customer load for any reason, the Company's intent is to curtail the appropriate amount of load
necessary to mitigate the situation. This is accomplished by selecting the amount or percent of load
reduction needed in the Energy Management System (EMS) Load Shedding application. The EMS
Load Shedding application allows the operator to select the applicable localized area or necessary
portions of the Company's service area to curtail the load. Load curtailment is accomplished manually
in areas that do not have SCADA connected to the EMS.
2. A range of curtailment stages associated with increasing levels of energy deficiencies
has been developed, incorporating North American Electric Reliability Corporation (NERC) standards.
The circumstances necessitating a reduction in the consumption of electricity in the short term will
normally require that immediate emergency action is taken and as such there may be little or no
warning. Sudden equipment outages or loss of generation could potentially lead directly to any
curtailment stage without prior notice or progression of the stages described below. These stages align
with the severity of the energy deficiency and are intended to minimize customer impact.
IDAHO
lssued per Order No
Effective -
lssued by IDAHO POWER COMPANY
Timothy E. Tatum, Vice President, Regulatory Affairs
1221 West ldaho Street, Boise, Idaho
ldaho Power Company
I.P.U.C. No. 29. Tariff No. 101 Orioinal Sheet No. J4
RULE J
CONTINUITY. CURTAILMENT AND
INTERRUPTION OF ELECTRIC
SERVICE
ROTATING OUTAGES AND ONGOING CURTAILMENT (Continued)
Stage Nature Type of Curtailment
1 All generation resources are committed.
Firm Customer load, firm transactions,
and reserve commitments are met.
Concerned about sustaining required
Contingency Reserves
o Non-firm wholesale energy saleso Ask Customers to voluntarily take
conservation measureso lssue communications notiffing
employees of the situation and asking
Company departments to reduce interna!
utilitv enerqv use.
2 ldaho Power is no longer able to
provide expected energy requirements
. Curtailment actions listed in Stage 1o lnterruptible Customer load and available
demand response programso lssue communications requesting
government agencies to implement their
programs to achieve necessary energy
reductions
3 ldaho Power is unable to meet minimum
Contingency Reserves as required by
NERC Standards
Curtailment actions listed in Stage 1 and
Stage 2
lmplement Emergency Load Shed and
Block Rotation
o
a
4 Emergency Load Shed due to
immediate risk posed to electrical
reliability.
a Applicable to all Customers. May be
limited to a specific location if reliability risk
is localto an area.
3. Demand response programs, if deployed as a required action under this plan, will not be
operated underthe provisions of Schedules 23,81, and 82. The provisions of Schedules 23,81, and
82, including but not limited to operating hours, notification requirements, and incentive payments wil!
not apply for any time period that the Company utilizes a Load Control Device installed under the
programs to interrupt a participating customer's load for an electric system emergency.
RETURN TO SERVICE
ldaho Power will return service to its Customers when:o The Company can meet its load and required operating reserves.o The reliability of the electric system will not be jeopardized.. Reliability Coordinator approval has been received, if applicable.
IDAHO
lssued per Order No.
Effective -
lssued by IDAHO POWER COMPANY
Timothy E. Tatum, Vice President, Regulatory Affairs
1221\Nest ldaho Street, Boise, ldaho
ldaho Power Company First Revised Sheet No. J-1
Cancels
!.P.U.C. No. 29. Tariff No. 101 Orioinal Sheet No. J-1
RULE J
CONTINUITY. CURTAILMENT AND
INTERRUPTION OF ELECTRIC
SERVICE
1. Electric Service is inherently subject to occasiona! interruption, suspension, curtailment,
and fluctuation. The Company will have no liability to its Customers or any other persons for any
interruption, suspension, curtailment, or fluctuation in service or for any loss or damage caused thereby if
such interruption, suspension, curtailment, or fluctuation results from any of the following:
a. Causes beyond the Company's reasonable control including, but not limited to,
fire, flood, drought, winds, acts of the elements, court orders, insunections or riots, generation
failures, Iack of sufficient generating capacity, breakdowns of or damage to facilities of the
Company or of third parties, acts of God or public enemy, strikes or other labor disputes, civil,
military or governmental authority, electrical disturbances originating on or transmifted through
electrical systems with which the Company's system is interconnected, and acts or omissions of
third parties;
b. Repair, maintenance, improvement, renewal or replacement work on the
Company's electrical system, which work in the sole judgment of the Company is necessary or
prudent; to the extent practicable work shall be done at such time as will minimize inconvenience
to the Customer and, whenever practicable, the Customer shall be given reasonable notice of
such work;
c. Actions taken by the Company, which in its sole judgment are necessary or
prudent to protect the performance, integrity, reliability or stability of the Company's electrical
system or any electrical system with which it is inter-connected, which actions may occur
automatically or manually.
2. fne orovislons ot t
3. Load curtailment an
authoritv shall fol lan-_as
iseienoutlined below*
The previeiens ef this rsle de net effeet any persens righte in tert,
IDAHO
lssued per Order No. 30508
Effective -+/la+eh4+O0g
lssued by IDAHO PO\A/ER COMPANY
, Vice President, Regulatory Affairs
1221 West ldaho Street, Boise, ldaho
ldaho Power Companv
|.P.U.C. No. 29. Tariff No. 101 Oriqinal Sheet No. J-2
RULE J
CONTINUITY, CURTAILM ENT AND
INTERRUPTION OF ELECTRIC
SERVICE
LOAD CURTAILMENT AND INTERRUPTION PLAN:
OVERVIEW
1. The Companv will complv with all state and federal mandates to curtai! the electric
enerqv used bv its Customers to orevent an electrical svstem collapse. Events that mav triqoer load
curtailment. either upon notice from state aoencies. the Reoional Reliabilitv Coordinator. or at the
discretion of the Companv. include but are not limited to:
a Fira fload rlrorroht winds oeneralinn faihrras lank nf crrffieient ncncratinn eanaeitv
equipment failures. qovernmental authoritv.
b. Actions taken to protect the oerformance, inteqritv. reliabilitv or stabilitv of the
Companv's electrical svstem or anv electrical svstem to which it is interconnected. which
actions mav occur automaticallv or manuallv.
c. Actions taken bv the Companv that in its sole iudoment are necessarv or prudent for the
safetv of people and/or equipment. or
d. Cvber-attacks or software failure of anv part of the Companv's oeneration. transmission.
and/or distribution svstem protection and/or control svstems.
davs.
AUTOMATIC, REMOTE AND MANUAL ACTIONS
1. Automatic actions occur throuoh the operation of proorammed protective equipment
installed on the Companv's electrical svstem. includino. without limitation. equipment such as automatic
relavs. oenerator controls. circuit breakers. and switches. This protection equipment is preset to
operate under certain prescribed conditions that, in the sole iudoment of the Companv. threaten svstem
performance. inteoritv, reliabilitv or stabilitv.
2. Where Supervisorv Control and Data Acouisition (SCADA) equipment is installed. the
Companv will remotelv control switches, circuit breakers. relavs, voltaoe reoulators or other equioment.
ln areas where no SCADA equipment is installed. actions are performed manuallv bv on-site field
oersonnel.
3. lf actions are undertaken. then to the extent oermitted bv the operatinq characteristics of
the electrical svstem. the Companv will perform such actions so that interruption. curtailment, or
fluctuation of service to customers will be accomplished sequentiallv. unless it is necessarv in the sole
iudoment of the Companv. or if required bv the Reoional Reliabilitv Coordinator to varv said sequence
in order to protect svstem performance. inteqritv, reliabilitv or stabilitv.
IDAHO lssued bv IDAHO POWER COMPANY
ldaho Power Companv
I.P.U.C. No. 29. Tariff No. 101 Orioinal Sheet No. J-3
RULE J
CONTINUITY. CURTAILMENT AND
INTERRUPTION OF ELECTRIC
SERVICE
CURTAILMENT AND INTERRUPTION
1. Curtailment and/or interruption of electric service can occur at anv time for a multitude of
situations. \Mren these situations arise, ldaho Power intends to take appropriate actions to mitioate the
situation for reliabilitv while maintainins service continuitv to as manv customers as oractical
Dependino on the nature of the situation. mitioation actions will ranoe from actions that will not affect
Customers to actions that curtail and/or interrupt seruice. impactinq localized areas and/or the entire
ldaho Power service area.
2. Idaho Power will promptlv notifv and keep state reoulatorv and reliabilitv authorities
informed of the curtailment and/or interruption to electric service.
ROTATING OUTAGES AND ONGOING CURTAILMENT
1. Curtailment and/or interruption of Customer load mav be necessarv to maintain the
reliabilitv of the electric svstem in certain situations. !n the event ldaho Power must curtail or interrupt
Customer load for anv reason. the Companv's intent is to cuftail the appropriate amount of load
necessarv to mitioate the situation. This is accomplished bv selectino the amount or percent of load
reduction needed in the Enerov Manaoement (trt\rs) I oad Shedrlino annlieation The FI\IS
Load Sheddinq apolication allows the operator to select the applicable localized area or necessarv
portions of the Companv's service area to cuftail the load. Load curtailment is accomplished manuallv
in areas that do not have SCADA connected to the EMS.
2. A ranoe of curtailment staoes associated with increasinq levels of enerqv deficiencies
has been developed, incorporatino North American Electric Reliabilitv Corporation (NERC) standards.
The circumstances necessitatinq a reduction in the consumption of electricitv in the short term will
normallv require that immediate emeroencv action is taken and as such there mav be little or no
warnino. Sudden equipment outaqes or loss of oeneration could potentiallv lead directlv to anv
curtailment staoe without prior notice or proqression of the staqes described below. These staqes alion
with the severitv of the enerov deficiencv and are intended to minimize customer impact.
ldaho Power Company
l.P.U.C. No. 29, Tariff No. 101 Oriqinal Sheet No. J-4
RULE J
CONTINUITY, CURTAILMENT AND
INTERRUPTION OF ELECTRIC
SERVICE
ROTATING OUTAGES AND ONGOING CURTAILMENT (Continued)
Stage Nature Tvoe of Curtailment
L All oeneration resources are committed.
Firm Customer load. firm transactions.
and reserve commitments are met.
Concerned about sustaininq required
Continqencv Reserves
. Non-firm wholesale enerov sales
o Ask Crrstom ers to voluntarilv take
conservation measuresr lssue communications notifvino
emplovees of the situation and askinq
Companv departments to reduce internal
utilitv enerqy use.
2 ldaho Power is no lonoer able to
provide expected enerov reouirements
Curtailment actions listed in Staoe 1ao lnterruptible Customer load and available
demand response programso lssue communications requestinq
qovernment aqencies to implement their
proorams to achieve necessary enerov
reductions
3 ldaho Power is unable to meet minimum
Continqencv Reserves as required bv
NERC Standards
Curtailment actions listed in Staoe 1 and
Staqe 2
lmplement Emerqencv Load Shed and
Block Rotation
a
4 Emeroencv Load Shed due to
immediate risk posed to electrical
reliability-
o Applicable to all Customers. Mav be
limited to a specific location if reliability risk
is localto an area.
3. Demand response oroqrams. if deploved as a required action under this plan. will not be
operated underthe provisions of Schedules 23.81. and 82. The provisions of Schedules 23.81, and
82, includino but not limited to operatinq hours. notification requirements, and incentive pavments will
not applv for anv time period that the Companv utilizes a Load Control Device installed under the
proqrams to interrupt a parti er's load for an electric svstem emeroencv
RETURN TO SERVICE
ldaho Power will return service to its Customers when:o The Companv can meet its load and required operatino reserves.. The reliabilitv of the electric svstem will not be ieopardized.. Reliabilitv Coordinator approval has been received. if applicable.
IDAHO lssued bv IDAHO POWER COMPANY
BEFORE TI{E IDAITO PT'BI,IC UTIIJITTES COMMISSTON
IN THE MATTER OF IDAIIO POWER
COMPANY'S APPLICATION FOR
APPROVAIJ OF ITS LOAD CTIRTAIIJMEI{'I
AI{D INTERRUPTION PI,A}I
IDA}IO POWER COMPAIVY
DIREqT TESTIMOIIY
KATHI,EEN AI{DERSON
cJtsE No. rPc-E-21-13
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L O. Please state your name, business address and
2 position with Idaho Power ("Idaho Power" or the "Company).
3 A. My name is Kathleen Anderson. My business address
4 is L221- West Idaho Street, Boise, Idaho 83702. My present
5 position is ReaI Tj-me Operations and Markets Senior Manager
5 in the Load Serving Operations Department.
7 Q. Please describe your educational background.
I A. In December of 2000, I received a Bachelor of
9 Administration degree in Finance from Boise State University
10 in Boise, Idaho. In September of 2005, I earned a Master of
l-l- Business Administration degree f rom the Unj-versity of
12 Phoenix. I hol-d a NERC System Operator - Reliability Operator
L3 (RC) certification. I obtained the initial certification in
14 2009 and renew it every 3 years after completing the
L5 continuing education requirements. The continuing education
1,6 reguirements include training hours dedicated to emergency
17 operations.
LB A. Briefly describe your work e>ryerience with Idaho
19 Power.
20 A. In 2005, I was hired as a Business Analyst in Idaho
2L Power's Delivery Finance Department. My primary
22 responsibilities included reviewing and granting credit to
23 entities wishing to conduct business under the Company's Open
24 Access Transmj-ssion Tarif f ("OATT'' ) . fn addition, f provided
ANDERSON, DI
Idaho Power Company
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L analyst support to the Company's Grid Operations Department,
2 assisting with budgeting and other financial and accounting
3 duties. In 2006, I transferred to the Grid Operations
4 Department as an Operations Analyst and was responsible for
5 aI1 contractual obligations of the Company's OATT.
6 In 2009, I became the System Operations Leader in the
7 Grid Operations Department and oversaw all day-ahead and
8 real-time activity conducted under the OATT, ds well as all
9 transmission contracts administered by the Grid Operations
10 and Load Serving Operations Departments. In 201-5, I was
11 promoted to the Transmission and Energry Scheduling Leader
12 where, in addition to my then-current duties, I assumed the
L3 oversight responsibility of the day-ahead balancing
14 operators.
15 In 201-8, f was promoted to the Transmission and Balancing
16 Operations Manag'er where I assumed responsibility for
L7 managing Idaho Power's real time system operati-ons which
18 includes transmission, generation dispatch and balancing
19 operations activities. In 2020, I was promoted to my current
20 position of Real Time Operations and Markets Senior Manager
2L where, in addition to my then-current duties, I assumed the
22 oversight of Idaho Power's participation in regional market
23 activities.
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AIiIDERSON, DI
Idaho Power Company
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1 O. What is the purpose of your testimony in t,his case?
2 A. The purpose of my testimony is to address the
3 Company's application to replace its Modified Regional Pl-an
4 and Electric Load Management Rule ,J Procedures ("Ru1e ,f
5 Procedures") with the Company's updated Load Curtailment and
5 Interruption P1an, ("LCIP").
7 Q. What prompted the Company to review its curtailment
I plan and procedures?
9 A. The original Modified Regional P1an, which focused
10 on long-term regional load curtailment, was developed in the
1l- early 1990s. Over time, changes in technology, modifications
1,2 to industry practices, and changes in generation capacity
L3 have served to make the existing Modified Regional Plan
14 obsolete. Further, industry developments, such as regional
15 resource adequacy concerns, wildfires and extreme weather,
16 growth in distributed energy, cybersecurity concerns, and
l7 failures of the interconnected grid elsewhere in the United
l-8 States have all contrj-buted to the development of updated
L9 J-ndustry standards and procedures to address curtailment and
20 interrupEion. Similar factors impact the need to update the
2l Company's Rul-e J Curtail-ment Procedures on f ile with the
22 Commission.
23 a. Please describe current industry practices related
24 to system reliability and operating standards.
ANDERSON, DI
Idaho Power Company
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1 A. Idaho Power complies with Federal Energy Regulatory
2 Commission (FERC) regulations and North American Electric
3 Reliability Corporation (NERC) reliability standards and is
4 a member of Ehe Western Electricity Coordinating Council
5 (WECC). The WECC is a Regional Entity given authority by the
5 NERC to monitor and enforces compliance. The Company also
7 supports Regional Reliability Coordj-nators, who monitor
8 voltages, freguencies, and other reliability indices. Ihe
9 Company's current reliability coordinator is RC West,
10 operated by the California Independent System Operator.
1l- Bulk electric system reliability and operating standards
12 for utilities in the western part of the United States provide
13 for a coordinated effort to effectively manage energy
L4 shortage situations, which includes: shedding firm load in an
15 emergency situation using the Company's under freguency
15 and/or under voltage load shedding programs to arrest
17 declining frequency; assisting recovery of frequency
1-8 following under frequency events; and providing last resort
19 system preservation measures to prevent a blackout or voltage
20 collapse.
2l Emergencies that threaten the integrity of the electric
22 system can develop at any time due to shortage of generation
23 or disturbances on the system, either 1oca11y or within the
24 Western fnterconnection. Ihe circumstances necessitating a
AI{DERSON, DI
Idaho Power Company
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1- reductj-on in the demand or consumption of electrj-city in the
short term will require that immediate emergency action is
taken and may potentially lead directly to firm load
curtai-Iment.
a. fs the 202! LCIP being submitted simply as a
modificatj-on of the Company's current curtailment plan and
procedures?
A. No. A 1ot has changed since the Modified Regional
Plan was filed in 1993 and the Rule ,J Curtailment Procedures
were last updated in 2002. As noted above, changes in
technology, industry practices, and generation capacity have
made the existj-ng Regional PIan obsolete. Although some
elements of the Modified Regional Plan are found within the
2027 LCIP, the existi-ng Modified Regional Plan and 2021- LCIP
vary enough in format and content that it reguired completely
re-writing the curtailment p1an.
O. Please summarize the elements of the 202L LCIP.
A. The 202L LCIP includes new provisions for load
reduction with demand response and emergency load shed
groups, and clarification regarding what entj-ties can
initiate load curtailment. It also covers a broader range of
events that can precipitate load curtailment activities. The
2021- LCIP combines elements of the Company's Rule J Procedures
and the Modified Regional P1an.
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Idaho Power Company
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O. Is the scope of the 2021- LCIP essentially the same
as the existing Modified Regional Curtailment Plan or the
Rule 'J Procedures?
A. No. The existing Modified Regional Curtailment Plan
addresses only long-term regional energy shortages,' L}:e 2021,
LCIP focuses on practical and actionable operational
activities the Company can initiate during emergencies to
minimize adverse impacts to customers and restore system
stability. The possible causes of a long-term energy shortage
described within the Modified Regional Plan include:
prolonged drought, severe operational constraints, or
moratoriums. This limited, narrow approach to curtailment
fails to provide direction for addressing more common
emergencies such as temporary loss of generation, failed
eqnipment, or extreme weather and temperatures. The 202L LCIP
is broader in scope, addressj-ng both long-term energy
shortages and temporary power interruptions due to
emergencies and system conditions.
O. Please summarize the curtailment stages identified
in the 202L LCIP.
A. The 2021, LCIP describes curtailment stages
associated with increasing energy deficits, estimated impacts
to customers and the methods that may be employed to reach
the reguired load curtailment necessary to stabilize the bulk
ANDERSON, DI
Idaho Power Company
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electrical system. These stages J-ncorporate corresponding
NERC Alert Ievels as defined in NERC Standard EOP-011-1,
notifications and reporting reguirements in each Energy
Emergency Alert 1eve1 for all applicable entities and
designated authorized parties and their respective
responsibilities .
O. What new provisions for curtailment sources are
included in the 202]- LCIP?
A. The 202L LCIP incorporates several new curtailment
sources, including demand response load control capabilities
and J-nterruptible customer load shed programs. Electric
service contracts with certain large customers may a11ow for
curtailment when the Company's contingency reserve,
transmission margin, or both are needed to meet system
demands. Interruptible Power Service gives the Company the
flexibility to curtail load as the first resource used when
immediate system stabilization is required. This provision
has been included in the 202]. LCIP.
The Company also has developed demand response programs
with its irrigation and residential customer groups that
al1ow the Company to cycle off participating customers during
peak load events using direct load control devices. In the
event of a system emerg'ency, the direct load control devj-ces
installed at customer locations could be activated to help
A}IDERSON, DI
Idaho Power Company
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1 manage 1oad. The Company also has a demand response program
2 available to its commercial and industrial customers that
3 reguires the customer (often an operations manager) to take
4 actj-on to reduce load at the site. The Company has
5 notification procedures in place and can use these tools to
5 activate an emergency event with these customers.
7 Q. Why is it important to recognize demand response
8 and interruptible loads and emergency load shed programs as
9 part of the 2O2l LCIP?
l-0 A. The Company has demand response prog'rams that can
1l- be caIled upon to achieve reductions in 1oad. The 202L LCIP
1,2 also makes use of the Company's load shedding application
13 within its Emergency Management System, and related load
14 shedding procedures, and block rotation, which provides for
15 rotational curtailments used in scheduled combi-nations until
L6 the necessary load curtailment j-s achieved. Block rotation
17 provides eqr:itable treatment to customers as the combination
18 of blocks curtailed is dependent on the day of the week and
19 time of day the curtailment is reguired. This method spreads
20 the impacts of curtailment to a broad base of customers so
2l that no particular group of customers is unduly impacted.
22 Where known and feasible within operational parameters,
23 distribution feeders serving facilities essential to the
24 public welfare are avoided during rotational curtailment.
AI{DERSON, DI
Idaho Power Company
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1- However, it should be noted that the Company cannot
2 definitively account for all such facilitj-es, nor is it
3 possible to exclude every known facility from the impacts of
4 curtailment.
5 Q. What types of entities may initiate load
5 curtailment under the 2021, LCIP?
7 A. Under the 2O2L LCIP load curtailment will be
8 initiated when directed by the Reliability Coordinator, who
t has been delegated this authority under NERC standards, by
l-0 order of the Commission, or by the Company at its own
1l- discretion. The long-term scope of the Modified Regional Plan
1,2 limited the initiation of load curtailment to "the state's
13 decTaration of an enerry emergency. " The Idaho Legislature
L4 delegated authority to declare such an emergency and initiate
15 load curtailment to the Commission under Idaho Code 551-533
16 and 561-534. In Idaho Power's Oregon service area, the
l7 Governor of Oregon is authorized to declare an energy
18 emergency under Oregon Revised Statutes L76.750 - 1-75.820.
L9 a. How does the Company plan to provide customers and
20 external State and regulatory stakeholders with information
21 during an emergency event?
22 A. Throughout the curtailment period the Company will
23 provide customers and exEernal State and regulatory
24 stakeholders with as much information as possible using
AI{DERSON, DI
Idaho Power Company
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1 established processes and protocols. The Company has
2 detailed Load Management Procedures (LMP) that describe roles
3 and responsibilities for communications during defined system
4 emergency events. The Company also has developed an Emergency
5 Response Communication Plan that provides detailed
6 responsibilitj-es and communications. During all sEages of an
7 emergency event, communication responsibilities are assigned
8 to specific individuals or departments for communication
9 within the Company, with regiulatory and reliability entities,
10 and with the general public.
11 Customers will be able to get outage information through
L2 customer service, online at idahopower.com, by subscribing to
l-3 text alerts and if warranted, public communication via medj-a
14 and social media outreach. Providing as much information as
15 possible on a timely basis to customers a1Iows customers to
16 be prepared as possible for a curtailment event and is another
L7 way the 2021- LCIP attempts to minimize the impacts of
LB curtailment.
L9 O. What is the Company's plan for providing updates to
20 the 202L LCIP?
2l A. In general, the 2021, LCIP is intended to broadly
22 address load curtailments and interruptions so as to not
23 require frequent updates, although the current state and
24 regional wildf ire and resource adeqr-racy ef forts may
AI{DERSON, DI
Idaho Power Company
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l- necessitate updates over the next few years. The Company has
2 detailed internal L,oad Management Procedures that support the
3 202L LCIP and are reviewed and updated at least annually to
4 ensure that the Company is fu11y prepared to deal with any
5 curtailment situations. As part of that annual review, the
6 Company intends to also review the LCIP and file updates with
7 the Commission as necessary.
8 Q. Please summarize why the Company is filing this
9 application reguest.ing Commission approval of its 2O2t LCIP
10 and modificatlons to RuIe J Continuity, Curtailment and
lL Interruption of Electric Service.
1,2 A. Since 1993, there have been changes in Company and
l-3 industry practices, technology, generation capacity, demand
14 response, and resource availability. The previously approved
15 Modified Regional Plan and the RuIe ,J Procedures no longer
16 represent how the Company addresses curtailment,
l7 necessitating a complete re-write of them. The Modified
L8 Regional Plan is only for long-term energy shortages and
L9 doesn't address short-term supply emerg'encies resultj-ng from
20 loss of major generation or transmission eguJ-pment, regional
2L operating standards, or weather extremes. The 2021- LCfP
22 addresses the Company's operational approach to:
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Initiation of Load Curtailment,
Automatic, Remote and Manual Actions,
Curtailment Stages,
A}IDERSON, DI
Idaho Power Company
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Interruptible Loads,
Block Rotation,
Emergency Load Shed, and
Return to Service.
The Company believes that the 202L LCfP is consistent
with the public health, safety and welfare, is technically
feasible to implement, and properly attempts to balance the
impact of any curtailments. Thus, the Company requests that
the Idaho Public Utilities Commission approve its 2O2L Load
Curtailment and Internrption PIan.
O. Does this conclude your testimony?
A. Yes.
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A}IDERSON, DI
Idaho Povrer Company
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]. DECIJARATION OF KAITILEEN A}IDERSON
2 I, Kathleen Anderson, declare under penalty of perjury
3 under the laws of the state of ldaho:
4 1. My name is Katshleen Anderson. I am employed by
5 Idaho Power Company as a ReaI Time Operations and Markets
5 Senior Manager in Power Supply.
7 2. On behalf of Idaho Power, I present this pre-
8 filed direct testimony in this matter.
9 3. To the best of my knowledge, my pre-filed direct
10 testimony is true and accurate.
1-1 I hereby declare that the above statement is true to
12 Ehe best of my knowledge and belief, and that I understand
l-3 it is made for use as evidence before the Idaho Public
t4 Utilities Commission and is subject to penalty for perjury.
L5 SIGNED this 11th day of May 2021-, ?t Boise, Idaho.
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Kathleen Anderson
A}IDERSON, DI
Idaho Power Company
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