20160225Comments.pdf

BRANDON KARPEN
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
(208) 334-03s7
IDAHO BAR NO. 7956
Street Address for Express Mail:
472W. WASHINGTON
BOISE, IDAHO 83702-5918
Attorney for the Commission Staff
IN THE MATTER OF THE APPLICATION OF
ROCKY MOUNTAIN POWER TO UPDATE
ELECTRIC SERVICE REGULATION NO. 13 .
CURTAILMENT PLAN FOR ELECTRIC
ENERGY.
frSCEIVED
2016 f[B 25 PH Z: 25
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BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
CASE NO. PAC.E.15-10
COMMENTS OF THE
COMMISSION STAFF
COMES NOW the Staff of the Idaho Public Utilities Commission, by and through its
Attorney of record, Brandon Karpen, Deputy Attorney General, and in response to the Notice of
Application and Notice of Modified Procedure issued in Order No. 33428 on December 3,2015,
in Case No. PAC-E-I5-10, submits the following comments.
BACKGROUND
On June 25,2015, Rocky Mountain Power ("Rocky Mountain" or "Company") filed an
Application seeking authority to update its Electric Service Regulation No. 13. Electric Service
Regulation No. 13 provides the Company's Curtailment Plan for Electric Energy. The Company
has proposed to update the Curtailment Plan to:
. include new provisions for load reduction with DSM and emergency load shed
groups;
. clarify the types of entities that can initiate load curtailment;o cover a broader range of events that can precipitate load curtailment activities; and,
. remove financial penalties.
STAFF COMMENTS FEBRUARY 25,2016
STAFF REVIEW
Staff reviewed the Company's Application and proposed Curtailment Plan ("Proposed
Plan") to determine if it conforms to the requirements of ldaho Code $ 6l -53 I and 61-532.
Idaho Code $ 6l-531 requires all electric corporations to maintain a plan or procedures for the
curtailment of electric consumption during emergencies. Idaho Code $ 6l-532 requires the plan
be submitted and reviewed by the Commission. The Commission must consider by statute, three
factors when evaluating such a plan: (l) the consistency of the plan with the public health, safety
and welfare; (2) the technical feasibility of implementation of the plan; and (3) the effectiveness
with which the plan minimizes the impact of any curtailment. Id. Staff evaluated the Proposed
Plan based on these three factors.
Consistency of the Plan with Public Health, Safety and Welfare
The Proposed Plan will be in effect 24 hours a day, 365 days ayear, to help ensure the
Company is able to:
o match customer demand and electrical supply generation;
o maintain the integrity of the electricity network;
. deploy available resources to restore electrical supply to normal as soon as is
practicable;
. apply existing processes to keep customers and stakeholders informed of the state and
progress of the incident or emergency;
o utilize communication avenues to appeal to customers to reduce energy consumption;
. coordinate with appropriate agencies to provide options to lessen the impact to
customers; and,
o meet applicable operating standards.
The Proposed Plan is written to address both long-term energy shortages and temporary
power interruptions due to emergencies or variations in system conditions. The Company's
Proposed Plan provides for rotational curtailments to minimize the impact of both long term
energy shortages and temporary power intemrptions. Rotational curtailment would be initiated
if, for example, there were reliability concerns with neighboring utilities or during localized
energy deficiencies. Production Response to IPUC Request Nos. 22 atd24. Rotational load
curtailment blocks of 100MW are used in the event of company-wide energy deficiencies. There
is one block that is less than 100 MW dedicated to Idaho, controlled by Supervisory Control and
Data Acquisition ("SCADA"). That block is capable of being dissected to reduce the amount of
STAFF COMMENTS FEBRUARY 25,2016
curtailment. The Company maintains that its ability to shed load within Idaho is determined
during the day of the curtailment event and is dependent upon the extent of the energy deficiency
and the affected area. Staffagrees it is appropriate for the Plan to address both long term and
short term curtailments that result in power outages because both may pose a risk to public
health, safety, and welfare.
The Proposed Plan states that, where possible, the Company will seek to avoid
curtailment of circuits that serve essential services during all rotational load curtailments.
Essential facilities identified by the Company include: hospitals, 911 centers, airports and FAA
facilities, large sewer and water treatment plants, major metropolitan downtown core areas,
facilities critical to electric system operation, prisons, police and fire stations including related
computer and communication centers, radio, TV news, emergency broadcast stations and
transmitting facilities, and U.S. military installations.
Staff notes that the Company includes a caveat within the Proposed Plan, that suggests
actual avoidance of essential services during rotational load curtailment may not be possible:
Where known and feasible within operational parameters, distribution feeders
serving facilities essential to the public welfare are avoided during rotational
curtailment. However, it should be noted that the Company cannot definitively
account for all such facilities, nor is it possible to exclude every known facility from
the impacts of curtailment.
Application, First Revision of Sheet No. 13R.4. The Company also states it has recently
conducted surveys to determine which distribution feeders in Idaho serve essential services. The
associated service transformers were marked and identified in the Company's mapping system as
critical loads with an associated ranking of importance. Staff supports these efforts based on the
potential improvements this information may pose for public health, safety, and welfare within
Idaho.
Staff also considered how the Company provides timely curtailment notif,rcation to
customers and regulatory stakeholders. Section five of Electric Service Regulation No. 13
presents the notifications and actions the Company will implement during curtailments. In
general, the target audiences for notifications are as follows:
o Stage 1: Intemrptible Loads and Demand Side Management - Public or news media are
not normally contacted.
o Stage 2: Public Appeal for Conservation - Public appeals for voluntary energy
conservation may be issued through media outlets, social media platforms, and automated
STAFF COMMENTS FEBRUARY 25,2016
outbound calling, at the Company's discretion; all nonessential Company use of power
will be curtailed, along with requests for the same from govemmental agencies,
nonessential use in all large buildings, and specifically requested major use customers.
Mandatory curtailment may be necessary by utilizing block rotation methods if additional
curtailment is required and intensified requests to the public are ineffective.
o Stage 3: Peak Load Curtailment - To the best of the Company's ability the Company will
contact key external stakeholders to inform them of imminent rotating outages. The
magnitude of the event will dictate the administrative level to which notifications will be
made. Key extemal stakeholders include, but are not limited to the Governor's office,
Utility Commissions, State energy/emergency response officials, Legislative leadership,
and key customer accounts.
o Stage 4: Block Load Curtailment - In addition to those actions taken under Stage 3, and
to the extent possible, customers in the areas targeted for rotating outages will be notified
and provided with an estimate of curtailment initiation and duration.
o Stage 5: Emergency Load Shed Groups - All internal and external notifications will
occur as soon as information is available.
The Proposed Plan states that the Company, to the best of its ability, will contact the
Commission prior to any rotating outages. Application, First Revision of Sheet No. 13R.6. Staff
notes that the State of Idaho is required to plan and prepare for disasters and emergencies that are
natural or man-caused. Idaho Code $ 46-1001, et seq. Additionally,Idaho Code $ 61-533
provides that the Commission shall have the authority to "declare an emergency" upon a finding
that an "inadequate or insufficiency of electric power and energy" threatens the health, safety
and welfare of the citizens of the state. This is important because the Commission is the
designated Energy Emergencies Coordinator (i.e., ID-ESF #12) for response and recovery efforts
dealing with significant disruptions in energy supplies for all hazardous emergency situations.l
Staff agrees that the Proposed Plan must appropriately address how the Company will
provide timely and accurate information to key audiences and stakeholders. Staff believes the
Proposed Plan reflects a public-private partnership. This public-private partnership relies on the
Company's roles and responsibilities as a supplier of energy in Idaho, and reflects the need for
I The Idaho Emergency Operations Plan delineates emergency response procedures, responsibilities, and lines of
authority using functional annexes that are assigned to lead coordinating agencies according to Idaho Code $ 46- I 00 I ,
et seq. ID-ESF #12 addresses the response and recovery efforts dealing with significant disruptions in energy supplies
for all hazardous emergency situations. Examples of hazardous energy emergency situations include physical
disruption of energy transmission and distribution systems, unexpected operational failure of such systems, planned
interruptions, or unusual economic or international political events.
STAFF COMMENTS FEBRUARY 25,2016
the Company to provide timely and accurate information, conduct assessments, prioritize its
response and conduct restoration efforts. Staff agrees with the Company's approach and
encourages the Company to continue to seek opportunities to participate in table top exercises
that support existing operations and notifications procedures.
Technical Feasibility of Plan Implementation
Staff reviewed the Company's Operating Standards and pertinent sections of the
Proposed Plan for technical feasibility. Section one of the Proposed Plan provides the purpose
and overview. Section two details the Company's use of automatic, remote, and manual actions.
Section three defines five curtailment stages that are associated with increasing energy deficits.
Finally, Section four describes how the initiation of load curtailment will utilize intemrptible
loads, block rotation, and emergency load shed groups.
The Proposed Plan presents how the Company's Operating Standards are subject to bulk
electric system reliability and operating standards. It also outlines a coordinated effort to
manage energy shortage situations and includes shedding firm load in emergency situations.
Application, First Revision of Sheet 13R.2. Staff believes it is appropriate for the Proposed Plan
to account for regional reliability operating standards and encourages the Company to continue
participating in the development and implementation of regional standards to ensure they are
technically feasible.
The Company participates in regional energy emergency planning and response programs
such as the Northwest Power Pool's (NWPP) Energy Emergency Plan (EEP)2 and the North
American Electric Reliability Corporation Q.,lERC)-coordinated GridEx.3 Staff believes
participation in these table-top exercises is one way the Company evaluates the technical
feasibility of the Proposed Plan. Staff encourages the Company to participate in these types of
exercises in the future.
2 EEP addresses FERC regulations that restrict the ways in which the various elements of the energy industry may
communicate, the role of the Peak Reliability Coordinator (RC) to increase the situational awareness and reliability
of the Western Interconnection, and the reliability standards and procedures that have been adopted by North American
Reliability Council (NERC) to mitigate and communicate reliability problems, including energy emergencies. The
Company participated in the 2015 EEP exercise sponsored by NWPP.
3 PacifiCorp participated in the GridEx III exercise sponsored by NERC on November l8-19,2015. GridEx III
simulated an unprecedented infrastructure crisis, with combined cyber and physical attacks on the North American
electric grid. A totalof 350 utilities from the U.S., Canada and Mexico took part in the exercise.
STAFF COMMENTS FEBRUARY 25,2016
The Plan's Effectiveness to Minimize the Impact of any Curtailment
The Company states that it determines the impact of a curtailment event on a case-by-
case basis in terms of the amount of load reduction required to resolve an electrical issue or
fulfill a mandate. Further, the curtailment blocks included in the plan include geographic
diversity so that not one community or county in the same service territory is impacted to a
greater extent than another. Staff generally agrees that successful implementation of block
rotation is one way the Company can minimizethe load that is curtailed and comply with
regional reliability standards.
Staff believes it is appropriate for the Company to employ both load reductions and
obtain increased generation (from internal or regional resources) to mitigate the need for
curtailments. The Company's Proposed Plan incorporates new curtailment sources such as DSM
capabilities and intemrptible customer load shed programs (e.g., Interruptible Power Service,
Electric Schedule No. 24). The Company states that these programs allow for curtailments when
the Company's spinning reserve, transmission margin, or both are needed to meet system
demands. Staff further observes that the Company utilizes intemrptible customer load as a 'first
resource' to avoid energy emergencies, which is consistent with regional energy emergency
plans. Staff agrees with this approach, particularly how the implementation of these programs
may minimize the load that is curtailed. Staff encourages the Company to ensure intemrptible
loads are available, and that it is technically feasible to use them, in the future.
The Company states that it also utilizes mutual aid agreements to lessen the impact of
major outage events caused by severe weather or other long-duration emergencies. Current
mutual aid agreements include: (1) Berkshire Hathaway Energy internal mutual aid agreement,
(2) Western Region Mutual Assistance Group, as lead by the Western Energy Institute, and (3)
Edison Electric Institute Mutual Assistance Agreement. Staff supports the Company's
participation in mutual aid agreements.
Staff believes the Company's efforts to comply with regional operation and contingency
standards mitigates and reduces the need for the Company to curtail firm load. Furthermore, the
Company relies, in part, on the Peak Reliability Coordinator's ("RC") model of the Western
Interconnection for operating standards implementation. See Application, First Revision to
Sheet l3R.l. Staff believes that a high quality and accurate representation of the Western
Interconnection by the Company and Peak RC will assist with situational awareness, operational
planning, seasonal preparedness, and outage management - such that, load curtailment amounts
STAFF COMMENTS FEBRUARY 25,2016
and frequency are further minimized. Staff encourages the Company to work with the Peak RC
to improve the reliability of the Western Interconnection and believes it is very important for the
Company to provide Peak RC with: (1) accurate load forecasts; (2) current and accurate remedial
action schemes; and, (3) all requested SCADA data including breaker/switch status and analog
measurements.
Planned Outaqes
Staff believes that the impact to critical services or at-risk populations may increase
during planned outages when environmental conditions dramatically change immediately
preceding or during the outage. These situations may not impact the operating standards or
reliability of the Company's distribution or transmission system, but they could impact the
health, safety, and welfare of Idaho citizens. Consequently, Staff examined the Proposed Plan to
ensure that the Company's procedures minimize the impact of any curtailment on customers,
including curtailment due to planned outages.
The Company's Customer Guarantees program includes plaru:ed outage notifications.
Company Regulation 25(d. Further, during this review of the Company's Proposed Plan, the
Company clarified that:
.. . planned outage notifications are delivered to impacted customers at least 48 hours
prior to the beginning of the planned outage time. If possible, large planned outages
affecting entire communities will be communicated with more advanced notice.
Each community in our service territory is assigned a customer and community
manager to act as the liaison to address any issues brought forward by city
leadership.
If scheduling allows, outage times are often scheduled to accommodate the
special needs of the affected community, examples of these special needs could be
limitations with water, sewer or special city events. In addition, and if scheduling
allows, outages impacting large industrial and commercial customers are scheduled
to coincide with their plan maintenance activities when possible. As an example,
the Company coordinates planned outages with Monsanto in Soda Springs, Idaho
to coincide with their internal maintenance schedules to lessen the impact.
For load curtailment events, efforts that include appropriate agencies are
undertaken to reduce the impact to customers. Examples of these efforts could
include re-configuration of the electrical network or working with inter-connected
entities to change relay settings or utilize emergency ratings for transmission lines
and transforners.
Production Response to IPUC Request No. 16. Staff believes the primary intent of the l3R
Curtailment Plan for Electric Energy is to address operations and communications during energ)
STAFF COMMENTS FEBRUARY 25,2016
emergencie^r. However, Staff also believes it is important for the Company to coordinate with
other entities to lessen customer impacts durrng planned outages. Staff acknowledges the steps
the Company takes in order to lessen customer impact during planned outages. Similar to energy
emergencies, Staff suggests the Company include emergency response personnel in the
communications protocols to further reduce potential impacts during large or extended planned
outages.
Removal of Financial Penalties
Previous Curtailment Plans approved by the Commission included pre-determined
financial penalties for customers that do not comply with State-initiated mandatory curtailments.a
However, in 1993 the Commission provided guidance on the issue of financial penalties stating
that:
It is our preference that the utilities do not file curtailment plans incorporating
the... (financial penalties)...of the Regional Curtailment Plan in its present form.
Conditions 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.
Order No. 25259, at2. Further, the current Curtailment Plan also contains pre-determined
financial penalties. The inclusion of these pre-determined penalties is contrary to Order No.
25634 (l.lovember 1993) in which the Commission approved the Company's Modified Regional
Plan where penalties for non-compliance was modified to read as follows:
The Commission will take whatever measures available and appropriate,
including the imposition of financial penalties, at the time of mandatory
curtailment is instituted to ensure that consumers comply with the mandates of the
plan.
Order No. 25634, at 7. The Company proposes to remove these requirements. The Company
states that it is unable to determine why the financial penalties provisions have not been
eliminated previously. The Company also states the financial penalty provisions in current
tariffs for Oregon, Washington, and California, which are similar to those in the current
Curtailment Plan, have not been applied. Staff evaluated the EEP and discovered that as it has
a Previously, the Company filed a Modified Regional Plan as its Curtailment Plan with the Commission in 1993. IPUC
Order No. 25634. The Commission adopted the Curtailment Plan during Case No. GNR-E-93-2, Order No. 25634.
In 2001, the Company filed an Emergency Management Plan for Commission review and approval. IPUC Order No.
28877.
STAFF COMMENTS FEBRUARY 25,2016
evolved over the years, it too has eliminated the role of financial penalties to achieve customer
load curtailments.
Staff agrees with the removal of the financial penalties. It appears the Company has the
ability to adequately curtail load through block rotations, DSM capabilities, intemrptible
customer load shed programs, and emergency load shedding, thus alleviating the need for
penalties to encourage mandatory load reductions by customers.
Updates to the Curtailment Plan
The Company states that, should any annual review or audit identify necessary changes
and updates to the Company's l3R Curtailment Plan for Electric Energy it will notifu the
respective Commission(s) of changes and submit the updated plan for approval. The Company
states that it also conducts audits and reviews its emergency plans developed in support of the
Proposed Plan. Staff believes the Company will continue to monitor its curtailment plan. Staff
also encourages the Company to participate in table-top exercises with emergency response
stakeholders to improve the Company's review of the Proposed Plan and the emergency plans
developed in support of the Proposed Plan.
RECOMMENDATIONS
Staff conducted a thorough review and believes that the Proposed Plan comports with
Idaho Code $$ 6l-531 and 6l-532. Consequently, Staff recommends approval of the
Company's Curtailment Plan for Electric Energy.
Respectfully submitted this Z5y day of February 2016.
Technical Staff: Johanna Bell
i:umisc/comments/pace I 5. I Obkmljb comments
STAFF COMMENTS FEBRUARY 25,2016
CERTIFICATE OF SER\ICE
I HEREBY CERTIFY THAT I HAVE THIS 25th DAY OF FEBRUARY 2016,
SERVED THE FOREGOING COMMENTS OF THE COMMISSION STAFF, IN
CASE NO. PAC.E.Is.IO, BY MAILING A COPY THEREOF, POSTAGE PREPAID,
TO THE FOLLOWING:
TED WESTON
ID REG AFFAIRS MANAGER
ROCKY MOLINTAIN POWER
I4O7 WEST NORTH TEMPLE STE 330
SALT LAKE CITY UT 84116
E-MAIL: [e-mail]
DATA REQUEST RESPONSE CENTER
E-MAIL ONLY:
datarequest@f acifi com.com
WONNE HOGLE
ROCKY MOUNTAIN POWER
1407 WEST NORTH TEMPLE STE 330
SALT LAKE CITY UT 84I 16
E-MAIL: wonne.hosel@pacifi corp.com
CERTIFICATE OF SERVICE