20211220Final_Order_No_35263.pdf

ORDER NO. 35263 1

Office of the Secretary
Service Date
December 20, 2021
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION

On May 11, 2021, Idaho Power Company (“Company”) applied for approval of its
2021 Load Curtailment and Interruption Plan (“LCIP”) and for authority to update its Electric
Service Rule J “Continuity, Curtailment, and Interruption of Electric Service” (“Rule J”). The
Company requested its Application be processed by Modified Procedure.
On July 13, 2021, the Commission issued a Notice of Application and set a deadline
for interested persons to intervene. Order No. 35101. The Idaho Irrigation Pumpers Association,
Inc. intervened.
On August 27, 2021, the Commission issued a Notice of Modified Procedure
establishing public comment and Company reply deadlines. Order No. 35149. Staff filed
comments to which the Company replied.
On September 28, 2021, Staff presented a memo asking if the Commission “wish[ed]
to hold a telephonic customer hearing pursuant to Idaho Code § 61-532.” The Commission
declined, citing the similarity of its Modified Procedure rules, IDAPA 31.01.01.201-.204., to a
customer hearing and the opportunity for interested persons to request a hearing under those rules.
Having reviewed the record in this case, we issue this Order approving the Company’s
Application.
THE APPLICATION
The LCIP combines elements of the Modified Regional Plan1 and Rule J Procedures.2
Prior to the LCIP, the Modified Regional Plan addressed only long-term regional energy shortages
and Rule J Procedures covered short-term emergencies. The LCIP combines both long and short-
term operational activities the Company can initiate during emergencies.

1 The Modified Regional Plan was originally filed in 1993 after the Commission required a modification to the
Regional Plan concerning non-compliance penalties. The Modified Regional Plan became the State Curtailment Plan.
See Order No. 25643.
2 Rule J Procedures are “high-level guidelines employed by the Company to temporarily interrupt 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.”
IN THE MATTER OF IDAHO POWER
COMPANY’S APPLICATION FOR
APPROVAL OF ITS LOAD CURTAILMENT
AND INTERRUPTION PLAN
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CASE NO. IPC-E-21-13

ORDER NO. 35263
ORDER NO. 35263 2

The LCIP addresses the Company’s operational approach to (1) initiation of Load
Curtailment; (2) Automatic, Remote, and Manual Actions; (3) Curtailment Stages; (4) Block
Rotation; (5) Emergency Load Shed Groups; and (6) Return to Service.
The 2021 LCIP incorporates the Company’s approach to dealing with Curtailment and
Interruption, including provisions for demand response and emergency shed groups, clarifying the
types of entities that can order the Company to initiate load curtailment and events that could
precipitate load curtailment activities.
Certain events can trigger load curtailment under the 2021 LCIP, including: (1) fire,
floods, drought, winds, generation failures, lack of generation capacity, equipment failures, and
governmental authority; (2) actions taken to protect the performance, integrity, reliability, or
stability of the Company’s—or any connected—electrical system; (3) actions taken by the
Company that it deems are necessary or prudent to protect people or equipment; and (4) cyber-
attacks or software failure of any part of the Company’s generation, transmission, or distribution
system protection or control systems.
THE COMMENTS
1. Staff Comments
Staff recommended the Commission approve the Company’s 2021 LCIP and update to
its Rule J. Staff believed the Company’s 2021 LCIP and updated Rule J meet the legal
requirements set forth in Idaho Code § 61-532 which requires the Commission to consider: (a) the
consistency of the plan with the public health, safety, and welfare; (b) the technical feasibility of
implementation of the plan; and (c) the effectiveness with which the plan minimizes the impact of
any curtailment.
Staff stated the Company’s update reforms its LCIP to work congruently with its Rule
J—which was last updated in 2002. Staff noted that the North American Electric Reliability
Corporation was granted authority to regulate bulk-power system planning and reliability
following the Company’s last update. This regulatory change alone provided justification for the
Company to update its plans.
Staff reviewed the notification procedures required by relevant state and regulatory
authorities. Staff also reviewed the Company’s Emergency Response Communication Plan
(“ERCP”) and believed it would benefit from additional detail regarding notification requirements
and communication protocols during curtailment, disaster, and emergency situations. Staff
ORDER NO. 35263 3

recommended the Company meet with relevant state agencies to develop a plan to clearly define
communication requirements and protocols to be exercised in the event of an emergency.
Staff was concerned that the Company did not solicit input from customers and other
stakeholders who would be impacted by a curtailment event. Staff believed the Company would
benefit from additional input and recommended the Company meet with PUC Staff, municipal
electric providers, electric co-ops, demand-side management participants, and other stakeholders
to improve the plan’s notification procedure to improve notification processes and minimize
stakeholder impacts during curtailment events.
2. Company Reply Comments
The Company responded to Staff’s recommendation for additional action by the
Company. The Company committed to relaying feedback to ensure its ERCP contains the
appropriate level of detail to maximize its effectiveness. Including meeting with Staff and
interested parties, the Company stated its plan to incorporate any enhancements into its annual
internal ERCP by early 2022. The Company also agreed to meet with Staff and other stakeholders
to improve the LCIP’s notification procedure to minimize impacts from future curtailments. The
Company anticipated holding discussions with stakeholders before summer 2022.
COMMISSION DECISION AND FINDINGS
The Commission has jurisdiction over this matter under Title 61 of the Idaho Code.
The Company is an electrical corporation and public utility. Idaho Code §§ 61-119 and -129. The
Commission is empowered to investigate rates, charges, rules, regulations, practices, and contracts
of public utilities and to determine whether they are just, reasonable, preferential, discriminatory,
or in violation of any provision of law, and to fix the same by order. Idaho Code §§ 61- 501, -502
and -503. Idaho Code § 61-532 requires the Commission to act upon curtailment plans submitted
by utilities by either adopting or rejecting the plans. Having reviewed the record, including the
Company’s 2021 LCIP and updated Rule J, we hereby approve the Company’s Application.
We appreciate the Company filing its updated curtailment plan for Commission review.
We find that updated curtailment plans are critical to ensuring reliable service to customers,
especially in times when transmission across the west is more constrained during periods of peak
demand. We also find that utilities having updated curtailment plans is in the public interest. We
encourage the Company to work with Staff and interested entities who might be affected during
curtailment events to update this Commission regarding its curtailment plans on a more regular
ORDER NO. 35263 4

reporting schedule. The Company should also work with Staff and interested parties to enhance its
communication and notification policies and procedures associated with the LCIP and ERCP.
O R D E R
IT IS HEREBY ORDERED that the Company’s Application is approved.
THIS IS A FINAL ORDER. Any person interested in this Order may petition for
reconsideration within twenty-one (21) days of the service date of this Order about any matter
decided in this Order. Within seven (7) days after any person has petitioned for reconsideration,
any other person may cross-petition for reconsideration. See Idaho Code § 61-626.
DONE by Order of the Idaho Public Utilities Commission at Boise, Idaho this 20th day
of December 2021.

PAUL KJELLANDER, PRESIDENT

KRISTINE RAPER, COMMISSIONER

ERIC ANDERSON, COMMISSIONER

ATTEST:

Jan Noriyuki
Commission Secretary

I:\Legal\ELECTRIC\IPC-E-21-13 Curtailment\orders\IPCE2113_final_dh.docx