20011030Order No 28877.doc

BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION

in the matter of THE APPLICATION OF pacificorp for approval of its revised emergency management plan. )
)
)
)
)
CASE NO. pac-e-01-10

ORDER NO. 28877

On June 13, 2001, PacifiCorp filed an Application requesting Commission approval of its Emergency Management Plan (the “Emergency Plan”). The Emergency Plan outlines procedures employed by the Company to temporarily interrupt electric service to its customers during emergencies and power shortages, and is intended to provide equitable procedures for the curtailment of power while minimizing adverse impacts to customers and maintaining overall system reliability.
On August 28, 2001, the Commission issued a Notice of Application, Notice of Modified Procedure seeking public comment on PacifiCorp’s Emergency Plan. Order No. 28822. Comments were to be filed no later than September 18, 2001. Only the Commission Staff filed comments.
BACKGROUND
PacifiCorp’s generation, transmission and distribution facilities serve approximately 1.5 million residential, commercial and industrial electric customers in the western United States. Headquartered in Portland, Oregon, PacifiCorp has more than 8,700 megawatts of generation capacity. PacifiCorp operates as Pacific Power in California, Washington, Oregon and Wyoming and as Utah Power in Idaho and Utah. PacifiCorp is also now part of the ScottishPower group, which provides energy and other utility services to 5.5 million customers in the United Kingdom.
PacifiCorp’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.
THE EMERGENCY MANAGEMENT PLAN
Although PacifiCorp’s operations are designed to provide a constant and reliable supply of electricity to its customers in a manner that safeguards the public and its employees, situations may arise that require it to interrupt service to its customers. For purposes of the Company’s Emergency Plan it states that incidents and emergencies outside its control occur from time to time which affect the quality and continuity of electrical supply. Examples of possible unforeseen incidents or emergencies are third party damage, vandalism, accidents severe weather and critical equipment failure. PacifiCorp states that in these situations it may be unable or deemed imprudent to supply the total demand requirements of its customers. The Company also states that a shortage of fuel for generation or other anticipated incidents could also cause the Company to use demand management to preserve fuel stocks for critical and essential services.
PacifiCorp’s Emergency Plan recognizes two categories of incidents and emergencies, Minor Incidents and Major Emergencies. The scale of the organization and arrangements will be adjusted accordingly to address each Minor Incident or Major Emergency. The Company states that by far the majority of occurrences initiating the Emergency Plan will be Minor Incidents that will be dealt with under its normal emergency service procedures that include proactive communicating with customers. In Major Emergencies, emergency service will require the support of additional resources and enhanced organizational arrangements.
Because these circumstances could arise at any time the Company states that its Emergency Plan is operational 24 hours a day, 365 days a year to:
Match customers’ demand and electrical supply generation;

Maintain the integrity of the electricity network;

Make available resources to restore supply quality to normal as soon as is practicable;
Keep customers informed of the state and progress of the incident or emergency;

Take steps for the care of its customers.

PacifiCorp Emergency Management Plan at page 1.
PacifiCorp’s Emergency Plan consists of four contingency plans that incorporate system-operating procedures for addressing system emergencies. Plan 1 is entitled “System Outages Emergency Procedures” and is meant to provide effective service to customers in response to a diminution of electrical supply quality due to damage or failure of critical plant and equipment.
Plan 2 is entitled “System Integrity Emergency Procedures” and sets out the actions to be taken to preserve the integrity of the transmission system if certain events occur. Plan 3 is entitled “Energy Supply Emergency Procedures” and establishes procedures for the long term restriction of demand or consumption of electricity by customers in the event of generating plant shortage, a fuel shortage, a combination of both of these circumstances, or for some other reason. Plan 4 is entitled “Black Start Emergency Procedures” and establishes procedures to follow in the event of a total collapse of the transmission system. Included in PacifiCorp’s Emergency Plan are two volumes that contain a directory of resources, load disconnect schedules and information detailing the Black Start restoration process.
In the event restrictions in demand/consumption of electricity is envisaged the curtailment plan will be implemented in three stages as described in NEEP. The three stages are consistent with NERC’s definition or criteria and 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.
PacifiCorp’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 PacifiCorp (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 Emergency 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. PacifiCorp will also notify the WSCC regional coordinator and the State Communications Center.
In the event that PacifiCorp 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 a 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 disconnection.
It is the Company’s intent to implement rotational disconnection in a fair and equitable manner, while maintaining system reliability. PacifiCorp’s service area is divided geographically into approximately 36 equal load groups. Critical load customers are not included in these load groups. A critical load customer is defined as a customer who supplies essential services relating to public health, public safety, welfare, or energy production. When implementing rotational disconnection, distribution circuits in each of the Curtailment Plan Load Groups will be curtailed. Outages are expected to last about two hours; however, factors like customer requirements, cold load pick-up, and crew availability will determine the actual outage duration. When possible, advanced notification will be provided to facilitate preparations and minimize the effect on customers. When rotational outages become necessary, or an emergency occurs, information will be disseminated through the Customer Service Center, telephone, e-mail, the Company Internet site, loud speaker and public announcements. Depending on the events that precipitate the various stages, the Northwest Security Coordinator, the Idaho State Communication Center, the U.S. Department of Energy, the Idaho Public Utilities Commission and large customers will be notified. The State Communication 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.
RELATIONSHIP TO OTHER PLANS
The Company’s Emergency Plan is also related to its 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 load 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.
THE COMMENTS
As previously mentioned, the only comments filed in this matter were submitted by the Commission Staff. Upon review of the Company’s Emergency Management Plan, Staff believed that the Plan is in the interest of the public health, safety and welfare. Furthermore, Staff believed that it is a workable plan and provides for an interface with existing plans and organizations. On these grounds Staff recommended approval of PacifiCorp’s Emergency Plan.

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 PacifiCorp’s Emergency Management Plan. We believe that the procedures adequately plan for both foreseen and unforeseen events. We further find that PacifiCorp’s Emergency Management Plan, 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 Emergency Management Plan 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.
O R D E R
IT IS HEREBY ORDERED that PacifiCorp’s Emergency Management Plan is approved.
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. PAC-E-01-10 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. PAC-E-01-10. 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 October 2001.

PAUL KJELLANDER, PRESIDENT

MARSHA H. SMITH, COMMISSIONER

DENNIS S. HANSEN, COMMISSIONER

ATTEST:

Jean D. Jewell
Commission Secretary

O:PACE0110_jh2

ORDER NO. 28877 1

Office of the Secretary
Service Date
October 31, 2001