20160503final_order_no_33519.pdf

Office of the Secretary
Service Date
May 3,2016
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION )
OF PACIFICORP DBA ROCKY MOUNTAIN )CASE NO.PAC-E-1540
POWER TO UPDATE ELECTRIC SERVICE )
REGULATION NO.13-CURTAILMENT )ORDER NO.33519
PLAN FOR ELECTRIC ENERGY )
On June 25,2015,PacifiCorp dba Rocky Mountain Power filed an Application seeking
authority to update and revise its Electric Service Regulation No.13 Curtailment Plan
(“Curtailment Plan”).Generally,the Curtailment Plan sets out the actions that the Company will
employ during periods when it experiences energy shortages.Rocky Mountain last filed a
Curtailment Plan with the Commission in 1993,and the current Application is the first update to
that plan.See Application at 2;Order No.25259.According to the Company,over the last 22
years,changes in technology,industry practices,and increases in generation capacity have made
the 1993 Curtailment Plan obsolete.
Rocky Mountain proposed to update the plan to include new provisions for load
reduction with demand-side management and emergency load shed groups,removal of financial
penalties,and clarification regarding what entity can initiate load curtailment.Shingleton Direct
at 2.Compared to the 1993 Plan,the proposed plan covers a broader range of events that could
lead to a load curtailment situation,incorporates new curtailment sources,and addresses long and
short-term supply emergencies.Id.at 2-5.
On July 22,2015,the Commission issued a Notice of Application and set an
intervention deadline of August 5,2015.No one applied for intervention.On December 3,2015,
the Commission issued a Notice of Modified Procedure.On February 25,2016,Commission Staff
filed the only comments in this matter;the Company did not file reply comments.
Based upon our review of the Application,Staff comments,and the applicable law,we
approve Rocky Mountain’s Application and adopt its proposed Curtailment Plan.
THE CURTAILMENT PLAN APPLICATION
Rocky Mountain used parts of the 1993 Plan as a starting point and combines elements
of the Company Emergency Management Plan filed in 2001.The Proposed Plan (“Plan”)
addresses long-term energy shortages and temporary power interruptions due to emergencies or
variations in system conditions.The Plan provides for rotational curtailments to minimize the
ORDERNO.33519 1
impact of both long-term energy shortages and temporary power interruptions.The Plan states
that the Company will seek to avoid curtailment of circuits that serve essential services during
rotational load curtailments,thus avoiding curtailment of hospitals.911 centers,airports,prisons,
and other vital facilities.
The Company claims that the Plan focuses on “practical and actionable operational
activities the Company can initiate during emergencies to minimize adverse impacts to consumers
and restore system stability.”Id.By way of summary,the Company claims the Plan will reflect
current technology,available resources,practices.and procedures.The Company also maintains
that the Plan aligns with its operational approach to load curtailment,and specifically addresses:
operation standards;proper initiation of load curtailment;automatic,remote,and manual actions;
various curtailment stages;interruptible loads;block rotation;emergency load shed groups;
minimization of potential impacts of curtailment;and notification issues.
Notably,Rocky Mountain also proposes elimination of portions of the 1993 Plan that
relate to financial penalties and how curtailment is audited and tracked.Id.at 3.The Company
argues that inclusion of financial penalties is inappropriate in light of Commission Order No.
25259,which stated “[the Commission’s]preference that utilities not incorporate monetary
penalties within their respective plans.”Id.
STAFF COMMENTS
Staff provided comprehensive comments on the Company’s approach.Staff agreed
with the projected application of the Plan and recommended approval.In comments,Staff
encouraged the Company to continue to seek tabletop exercises that will improve operations and
notification procedure;develop refined regional standards;explore additional load shed programs;
and incorporate better data into the Peak Reliability Coordinators Western Interconnection model
to increase situational awareness and reliability.
Upon a thorough review of the Company’s Plan,Staff believes that the Plan is in the
public interest and promotes the public health,safety and welfare.Staff also maintained that the
Plan is workable and technically feasible and that the Plan would minimize the impacts on
customers relating to curtailment actions taken by the Company.On these grounds,Staff
recommended approval of Rocky Mountain’s Curtailment Plan.
ORDER NO.33519
LEGAL STANDARD
Idaho Code §61-531 requires all electric corporations to maintain a plan or procedure
for the curtailment of electric or gas consumption during emergencies.Idaho Code §61-531-
532 requires these procedures be submitted and reviewed by the Commission.In reviewing the
curtailment 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.
DISCUSSION AND FINDINGS
A.Public Health,Safety and Welfare
We find that the Plan adequately addresses the Company’s responses to both long-term
and temporary power shortages/interruptions.The Plan states that the Company will endeavor to
contact the Commission prior to any outages.See Application,First Revision of Sheet No.1 3R.6.
Such reporting is significant because the Commission is the designated Energy Emergencies
Coordinator for response and recovery efforts dealing with significant disruptions in energy
supplies for all hazardous emergency situations.See Idaho Code §46-100 1.
We further find that the Company’s Plan is consistent with maintaining public health,
safety and welfare.Specifically,the Plan adequately addresses maintaining circuits that serve
essential services.Regarding essential services,we recognize that total avoidance of curtailment
actions is not always possible,but we expect Rocky Mountain to take serious its commitment to
identify and avoid curtailment of circuits that serve essential services.The plan identifies a
reasonable approach for notifying customers and other stakeholders about curtailment events.
Consequently,we find that the Plan reflects acceptable and prudent practices for curtailment.
B.Technical Feasibility
We find implementation of the Plan technically feasible.It outlines standard
procedures and actions that may be taken to manage short and long-term energy shortages through
the use of interruptible loads,block rotation,and emergency load shed groups.It also outlines a
coordinated strategy to manage energy shortage situations,including shedding firm load (i.e.,non
interruptible customers)in emergency situations.The Company states in its Application that it
continually evaluates its operations through tabletop exercises and participation in regional energy
ORDERNO.33519 3
emergency planning and response programs.Furthermore,the Plan that is being replaced is
obsolete,making it unfeasible.
C.Minimize the Impact
While the impact of any curtailment event can only be evaluated on a case-by-case
basis,the Proposed Plan intends to curtail geographically diverse curtailment blocks of customers
to avoid one area being curtailed more than another,should the need for curtailment arise.Further,
when compared to the 1993 Plan,the Proposed Plan incorporates alternatives to typical
curtailment,such as DSM capabilities and interruptible customer load shed programs.According
to the Company,these programs allow for curtailments when the Company’s spinning reserve,
transmission margin,or both,are needed to meet system demands.The Proposed Plan also utilizes
interruptible customer load as a “first resource”to avoid energy emergencies.We find this
consistent with regional energy emergency plans and in the public interest.Finally,the Company
states that it will continue to utilize mutual aid agreements to lessen the impact of any major outage
or energy emergency.
We find the Proposed Plan adequately minimizes the impact of curtailment on its Idaho
customers.We encourage the Company to continue exploring alternative curtailment sources and
refining regional standards to ensure both feasibility and to minimize customer impacts.
D.Financial Penalties
The 1993 Plan includes pre-determined financial penalties for customers that do not
comply with State-initiated mandatory curtailments.See Order No.25634.The Commission has
previously stated that “[ut is our preference that the utilities do not file curtailment plans
incorporating the [financial penalties]of the Regional Curtailment Plan....“Order No.25259 at
2.We have noted that “[c]onditions could change between now and when mandatory curtailment
becomes a necessity such that the imposition of monetary penalties is unwarranted or the amount
of the penalties is inappropriate.Id.The Company proposes to remove these penalties going
forward.We find that the removal of financial penalties is appropriate.
In summary,we find that the Plan contains appropriate procedures for the Company
to temporarily interrupt electric service to its customers during emergencies and power shortages.
We further find that the Plan provides equitable procedures for the curtailment of power,it
minimizes adverse effects to customers,and it strives to maintain system reliability.The Plan
contains specific procedures to guide the Company’s response from the time a potential problem
ORDERNO.33519 4
is identified until service is restored to normal.We conclude that Rocky Mountain’s proposed
Curtailment Plan is consistent with the public health,safety and welfare;its implementation is
technically feasible;and it minimizes the impacts of any curtailment action.
We encourage and look forward to more frequent updates by all utilities regarding
their curtailment plans.Updates and changes to curtailment plans should reflect actual practices
and be regularly updated.We applaud continued exploration of new curtailment sources and
efforts by Rocky Mountain to implement curtailment in a way that minimizes the impact on
customers.
ORDER
IT IS HEREBY ORDERED that the Curtailment Plan filed June 25,2015,by
PacifiCorp dba Rocky Mountain Power is approved and adopted effective immediately.
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.Within seven (7)
days after any person has petitioned for reconsideration,any other person may cross-petition for
reconsideration.See Idaho Code §6 1-626.
ORDERNO.33519 5
DONE by Order of the Idaho Public Utilities Commission at Boise,Idaho this
da of May 2016.
PAUL KJELLADE ,PRESIDENT
4)i4Q\
KRfSTINE RAPER,CO IMISSIONER
ERIC ANDERSON,COMMISSIONER
ATTEST:
4J
Jn D.Jewel!(I
iOmrnission Sretary
():PAC-E-15-lObk3
ORDERNO.33519 6