20210922Comments.pdf

DAYN HARDIE
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTTLITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 9917
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Street Address for Express Mail:
I I331 W CHINDEN BLVD, BLDG 8, SUITE 201-A
BOISE, ID 83714
Attorney for the Commission Staff
BEFORE THB IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF IDAHO POWER
COMPANY'S APPLICATION FOR
APPROVAL OF ITS LOAD CURTAILMENT
AND INTERRUPTION PLAN
CASE NO. IPC.E.?I-I3
COMMENTS OF THE
COMMISSION STAFF
STAFF OF the Idaho Public Utilities Commission, by and through its Attorney of
record, Dayn Hardie, Deputy Attorney General, submits the following comments.
BACKGROUND
On May 11,2021, Idaho Power Company ("Company") applied for approval of its 2021
Load Curtailment and Intemrption Plan and for authority to update its Electric Service Rule J-
Continuity, Curtailment, and lntemrption of Electric Service ("Rule J"). The Company
requested its Application be processed by Modified Procedure.
The Application summarizes the Company's curtailment plan background and reasoning
for the 2021Load Curtailment and Intemrption Plan ("LCIP") and its Electric Service Rule J-
Continuity, Curtailment, and Intemrption of Electric Service. The Application also includes
differentiation between the LCIP and the Modified Regional Plan. The Company's current
curtailment plans include following the Electric Load Management Rule J Procedures last filed
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ISTAFF COMMENTS SEPTEMBER 22, 2O2I
in2002 and elements of the Modified Regional Plan filed in 1993. The Company's filing is
made pursuant to ldoho Code $ 6l-531, Plan for Curtailment of Electric or Gas Consumption,
that requires all suppliers of electric power and energy to file a plan for curtailment with the
Commission.
STAFF REYIEW
Staff reviewed the Company's Application for approval of its LCIP and for authority to
update its Rule J. Based on its review, Staff recommends the Commission approve the 2021
LCIP and to update Rule J.
Compliance
The Company's2021LCIP and update to Rule J meet the legal requirements set by
Idaho Code S 6l-532. To meet the requirements, the Commission shall 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 reviewed the Company's 2021updates and determined that the Company followed
the requirements of ldaho Code $ 61-532. The Company's update reforms its LCIP to work in
conjunction with its Rule J. The Company's Rule J was updated in2002 and the Modified
Regional Plan was filed in 1993. Since the Company's last update, the North American Electric
Reliability Corporation has been granted authority to regulate bulk-power system planning and
reliability. Both regional and regulatory changes create sufficient reasons for an update of plans
to meet public health, safety, and welfare. Previous plans and rules set by the Company require
updates to meet current industry practices and regulations. The Company has requested approval
to update its plans to satisff practices and procedures. Staff found that the 2021LCIP
adequately plans for curtailment-related emergency events and reduces the impact on customers.
Notification
Staff reviewed the notification procedures pertaining to state regulatory and reliability
authorities. Staff asked the Company to describe how it provides notification of curtailment or
2STAFF COMMENTS SEPTEMBER22,2O2I
interruption to state regulatory and reliability authorities. The Company provided the following
response. Productton Request and Company Response No. 2.
The primary state regulatory authorities notified would be the Idaho
Public Utilities Commission and/or the Public Utility Commission of
Oregon. Under the Company's Emergency Response Communication Plan
("ERCP"), provided as a Confidential attachment to this request, the
designated Communication Coordinator notifies several critical internal
groups including the Legal and Regulatory Affairs departments. If
circumstances giving rise to the interruption or curtailment are likely to be
of significant public impact or attention, Regulatory Affairs will contact the
Idaho Public Utilities Commission ("IPUC") and/or Public Utility
Commission of Oregon ("OPUC") to notifu them of the event and provide
updates as the situation warrants.
Further, the Company's Emergency Management Team ("EMT") will
contact the Idaho and Oregon Offices of Emergency Management
depending on the type and severity of the event. The role of the EMT will
depend on if the event impacts the continuity of critical business functions
and/or the severity of the event.
These types of communications are envisioned to occur via direct phone
call, so the Company does not have record of specific communications to
state regulatory and reliability authorities.
Staff reviewed the Company's ERCP and believes the document could benefit from
additional detail regarding notification requirements and communication protocols used during
curtailment, disaster, and emergency situations. Staff recommends that the Company meet with
IPUC Staff, the ldaho Office of Emergency Management, and Emergency Support Function
("ESF") #12 (Energy) and develop a plan to clearly define communication requirements and
protocols to be exercised in the event of an emergency or disaster.
In response to Production Request Nos. 3, 5, and 6, Staff learned that the Company did
not solicit input from its customers and other stakeholders that are directly impacted by
curtailment in development of its proposed updates to the LCIP. Staff believes the Company
could benefit from such input and recommends that the Company meet with IPUC Staff, electric
providing municipalities, electric cooperatives, DSM participants, and other stakeholders to
improve upon the plan's notification procedures to minimize stakeholder impact of future
curtailments.
JSTAFF COMMENTS SEPTEMBER22,2O2I
STAFF RECOMMENDATIONS
Staffrecommends the Commission approve the202l LCIP and update to its Electric
Service Rule J - Continuity, Curtailment, and Intemrption of Electric Service.
Staff also recommends that the Company meet with Staff and interested parties to gather
feedback and to update notification procedures based on the feedback.
"ncRespectfully submitted this Lt-- day of September 2021.
Dayn
Deputy Attorney General
Technical Staff: Josh Haver
Kevin Keyt
Daniel Klein
Taylor Thomas
Yao Yin
i:umisc/commentVipce2 l. l3dhjh comments
4STAFF COMMENTS SEPTEMBER2Z,2O2I
CERTIFICATE OF SERYICE
I HEREBY CERTIFY THAT I HAVE THIS 22ND DAY OF SEPTEMBER 2021,
SERVED THE FOREGOING COMMENTS OF THE COMMISSION STAFFN IN
CASE NO. IPC-E-21.13, BY E-MAILING A COPY THEREOF, TO THE FOLLOWING:
LISA NORDSTROM
IDAHO POWER COMPANY
PO BOX 70
BOISE ID 83707-0070
E-MAIL : [e-mail]
dockets@idahopower. com
CONNIE ASCHENBRENNER
IDAHO POWER COMPANY
PO BOX 70
BOrSE rD 83707-0070
E-MAIL : [e-mail]
J",4u,.-,
SECRETARY
CERTIFICATE OF SERVICE