10032001Decision Memo.doc

DECISION MEMORANDUM

TO: COMMISSIONER KJELLANDER
COMMISSIONER SMITH
COMMISSIONER HANSEN
JEAN JEWELL
RON LAW
BILL EASTLAKE
LOU ANN WESTERFIELD
LYNN ANDERSON
DON HOWELL
RANDY LOBB
DAVE SCHUNKE
TONYA CLARK
BEV BARKER
GENE FADNESS
WORKING FILE

FROM: JOHN R. HAMMOND

DATE: OCTOBER 3, 2001

RE: IN THE MATTER OF THE APPLICATION OF PACIFICORP FOR APPROVAL OF ITS REVISED EMERGENCY MANAGEMENT PLAN.
CASE NO. PAC-E-01-10

BACKGROUND
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.
Notice of Application, Notice of Modified Procedure was issued on August 28, 2001. Order No. 28822. Staff was the only party to submit written comments.
THE EMERGENCY PLAN
The Company states the 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’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.
The above plans recognize two categories of incidents and emergencies, minor incidents and major emergencies. If either of these events occur, the Company has established detailed procedures so that these situations may be dealt with under one of its proposed contingency plans. Also 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.
The Company clarified by letter dated September 24, 2001, that the Emergency Plan is consistent with the “Northwest Energy Emergency Plan” (NEEP), and NERC rules. The letter also explains that Plan 3 is intended to substantially replicate the function of the “Regional Curtailment Plan” (RCP)
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, 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.
STAFF RECOMMENDATIONS
The Company’s Plan implements practices normally utilized by the electric industry to avoid rolling outages. If rolling outages become necessary, the Plan provides for an orderly, nondiscriminatory process to reduce load and to provide notification. The Plan employs both load reduction and increased generation measures to mitigate curtailments. In the event that rolling outages become necessary, Staff believes that spreading outages evenly across the 36 load groups is equitable and fair. The planned curtailments of about two hours appropriately balance the need to safeguard system reliability while minimizing adverse impacts to customers.
Upon review of the Company’s Emergency Management Plan, Staff believes that the Plan is in the interest of the public health, safety and welfare. Furthermore, Staff believes that it is a workable plan. It provides for an interface with existing plans and organizations. Staff recommends approval of the Company’s Emergency Plan.
COMMISSION DECISION
Does the Commission wish to approve PacifiCorp’s Emergency Management Plan?

John R. Hammond

Staff: Dave Schunke

DECISION MEMORANDUM 4