20220427Comments.pdf

RILEY NEWTON
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. II2O2
Street Address for Express Mail:
I 1331 W CHINDEN BLVD, BLDG 8, SUITE 2OI-A
BOISE, ID 83714
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF ROCKY MOUNTAIN
POWER'S APPLICATION TO UPDATE
ELECTRICAL SERVICE REGULATION
NO. 13 _ CURTAILMENT PLAN FOR
ELECTRIC ENERGY
CASE NO. PAC-E-22-04
COMMENTS OF THE
COMMISSION STAFF
STAFF OF the Idaho Public Utilities Commission, by and through its Attomey of
record, Riley Newton, Deputy Attorney General, submits the following comments.
BACKGROUND
On February 22,2022, Rocky Mountain Power, a division of PacifiCorp ("Compffiy"),
applied to the Commission for authorizationto update Electric Service Regulation No. 13,
Curtailment Plan for Electric Energy ("Curtailment Plan"). Application at l. The Company
requested its Application be processed by Modified Procedure with a June 1, 2022, effective
date.
The Company represents that it developed its Curtailment Plan to deal with energy
shortages by temporarily intemrpting electric service. Id. at2.
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ISTAFF COMMENTS APRIL 27,2022
The Company states that its Curtailment Plan consists of five stages, each of which are
designed to provide equitable procedures meant to minimize adverse impacts to customers while
maintaining overall system reliability. Id. at3.
The Company requests the Commission approve the updates to its Curtailment Plan. The
proposed updates include removing the reference to "intemrptible customer load shed" in Stage
l, and removing a section subtitled "Interruptible Loads" in Section IV of the Curtailment Plan.
Id. at 5. The Company represents that, in addition to "other minor edits," it replaced the
reference to the "Peak Regional Reliability Coordinator" with the "RC West Regional Reliability
Coordinator" and corrected the reference to the Idaho Public Utilities Commission. Id.
STAFF REVIEW
Staff reviewed the Company's Application for approval of its updated Electric Service
Regulation No. 13, Curtailment Plan for Electric Energy. Based on its review, Staff recommends
the Commission approve the updates to Electric Service Regulation No. 13.
Compliance
In acting upon a curtailment plan, the Commission shall consider the following factors:
(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. Idaho Code $ 6l-532.
Staff reviewed the Company's updates and believes the Company's Curtailment Plan
satisfies the factors under ldaho Code $ 6l-532. The Company's update reforms its Curtailment
Plan to remove a large intemrptible customer ("Bayer")l from the Stage 1 category. In Case
No. PAC-E-21-07, the Company filed an Electric Service Agreement ("ESA") with Bayer.
Within the ESA, is a change in the terms of the customer's curtailment products and the
customer's requirements. As stated in response to Production Request No. 2, o'the only change to
Electric Service Regulation No. 13, is to remove this large industrial customer from Stage I
I In the current Application, the Company states it filed "a new conhact with the large industrial customer resolving
the curtailment terms of this interruptible customer's energy service agreement" in Case No. PAC-E-21-07- In the
Mqtter of the Applicotion of Rocky Mountain Power for Authority to Increase lts Rates and Charges in ldaho and
Approval of Proposed Electric Service Schedule and Regulations. Application at 4, frr. 3. The Direct Testimony of
Mike Veile in Case No. PAC-E-21-07 makes clear that the "large intemrptible customer" with whom the Company
has a curtailment plan is Bayer.
2STAFF COMMENTS APRIL 27,2022
category." In Veile's Direct Testimony in support of the settlement agreement in PAC-E-21-07,
he states that the previous ESA with Bayer provided the Company 95 megawatts ("MW") of
operating reserves and 67 MW of economic curtailment. Veile goes on to state that the
Company also had the right, under the previous ESA, to interrupt Bayer a total of 1,000 hours
annually, consisting of 12 hours of system integrity intem:ptions at 162 MW, whereas under the
new ESA, the system integrity curtailment product has been eliminated.
In Order No.35277, the Commission found the changes in the ESA reasonable, the
Company is now obligated to update the Electric Service Regulation No. l3 and has filed
updates with the Commission. Thus, Staff supports the Company's updates to the ESR.
Notification
Staff reviewed the notification procedures pertaining to state regulatory requirements and
believes the procedures are sufficient in detail regarding notification requirements and
communication protocols. The Company described how it provides external notifications of
curtailment. See Production Request No.9. The Company provided a confidential plan that
elaborates the Energy Emergency Communications Protocol. There is also a current procedure
in which any real time load curtailments to the electric system are communicated with the
Reliability Coordinator and outages in Idaho are automatically communicated to the Idaho Public
Utilities Commission ("IPUC").
In developing its proposed updates to the Curtailment Plan, the Company did not solicit
additional input from customers and other stakeholders who are directly impacted by
curtailment. In response to Production Request No. 2,the Company stated:
The large industrial customer participated in contract negotiations with the
Company that resulted in the elimination of the System Integrity product
from its intemrptible contract. Other than minor housekeeping edits, the
only change to Electric Service Regulation No. 13 is to remove this large
industrial customer from the Stage I category as an intemrptible customer
load shed.
The Company could benefit from such input for the next update by meeting with electric
municipalities, electric cooperatives, DSM participants, and other stakeholders to improve upon
the Curtailment Plan to minimize the impact of future curtailments on stakeholders. Staff
believes the notification procedures regarding the IPUC could be updated to improve
communication.
JSTAFF COMMENTS APRIL 27,2022
STAFF RECOMMENDATIONS
Staff recommends the Commission approve the updated Electric Service RegulationNo. 13,
Curtailment Plan for Electric Energy.
Staff recommends the Company meet with interested electric stakeholders and allow input
on future Curtailment Plan updates.
Staff also recommends the Company meet with Staffto review and update notification
procedures regarding the IPUC.
?TRespectfully submitted this day of April2022.
Riley
Deputy Attorney General
Technical Staff: Josh Haver
Travis Culbertson
i:umisc/commentVpace22.4rnjhtnc comments
4STAFF COMMENTS APRIL 27,2022
CERTIFICATE OF SERYICE
I HEREBY CERTIFY THAT I HAVE THIS 27th DAY OF APRIL 2022,
SERVED THE FOREGOING COMMENTS OF TIIE COMMISSION STAFF, IN
CASE NO. PAC-E-22-04, BY E-MAILING A COPY THEREOF, TO THE
FOLLOWING:
TED WESTON
ROCKY MOUNTAIN POWER
I4O7 WEST NORTH TEMPLE STE 330
SALT LAKE CITY UT 84I16
E-MAIL: [e-mail]
idahodockets@pacifi com.com
DATA REQUEST RESPONSE CENTER
E.MAIL OIILY:
datarequest@pacifi corp.com
EMILY WEGENER
ROCKY MOUNTAIN POWER
1407 WN TEMPLE STE 320
SALT LAKE CITY UT 84116
E-MAIL: [e-mail]
SECRETAR
CERTIFICATE OF SERVICE