20100927_3093.pdf

DECISION MEMORANDUM
TO:CO MMISSI 0 NER KEMPTON
COMMISSIONER SMITH
COMMISSIONER REDFORD
COMMISSION SECRETARY
LEGAL
WORKING FILE
FROM:T J GOLO
DATE:SEPTEMBER 24,2010
RE:ADDITION OF CLARIFYING LANGUAGE TO ALL IDAHO POWER'
RESIDENTIAL SCHEDULES, TARIFF ADVICE NO. 10-02.
BACKGROUND
On August 24, 2010, Idaho Power ("Company ) filed a tariff advice proposing to add
clarifying language to the Water Heating section of Schedule 1 - Residential Service, Schedule 3
- Master Metered Mobile Home Park Residential Service, Schedule 4 - Energy Watch Program
Residential Service, and Schedule 5 - Time-of-Day Program Residential Service. Since 1971
the Water Heating section has identified conformance and sizing restrictions for electric water
storage heating equipment but has not specifically addressed newer technologies like tankless hot
water heating systems.
Over the past several years, the promotion and installation of residential tankless electric
hot water heaters has increased and, in many cases, necessitated upgrades to the Company
facilities in order to meet the electrical demand requirements of these systems. Under Section 3
of Rule K (Change of Load Characteristic), customers are required to notify the Company prior
to making significant changes in the amount or character of their electrical load. The proposed
additional language specifically identifies electric storage and tankless hot water heating systems
and outlines customers' responsibility to pay for all nonstandard upgrades to Company
electrical facilities, consistent with Rule H (New Service Attachments and Distribution Line
Installations or Alterations) provisions.
DECISION MEMORANDUM - 1 -SEPTEMBER 24 2010
STAFF REVIEW
The Company typically receives one to two inquiries per month related to an installation
of electric tankless hot water heaters. The Company performs an upgrade of facilities one to two
times per year from installations of electric tankless hot water heaters. The typical facilities
required to be upgraded due to installation of electric tankless hot water heaters include, but are
not limited to, transformers and service wire. Staff believes that the proposed language in the
Company s Water Heating section under Schedules 1 , 3, 4, and 5 adds clarity to electric water
heating restrictions and specifies under what conditions new facilities will be required. With the
addition of the proposed language, customers who installed electric water heaters that do not
comply with the specifications as outlined in the tariff will bear the upgrade costs, rather than
burdening other ratepayers.
COMMUNICATION EFFORT
The Company identified that a licensed plumber is needed to complete the installation of
the tankless water heaters. The Company intends to send a postcard to licensed plumbers, which
will contain information about the possibility ofthe need for an upgrade due to inadequate
capacity from the existing service when installing an electric tankless hot water heater. Unless
the homeowner is capable of doing the work, a plumber has to re-configure the plumbing system
to accommodate the electric tankless water heater. They expect the plumbers to pass on the
Company s concern whenever they are contacted to install this type of water heater. In addition
customer representatives from the Company will personally visit large home improvement stores
such as Lowe s and Home Depot along with smaller local stores and be given a set of postcards
to distribute to customers who consider installing tankless water heaters. The postcard also
suggests contacting the Company before buying an electric tankless water heater for a free
electrical assessment. The Company hopes that these post cards be placed near the tankless
water heaters but this may not always be possible because stores have different policies.
STAFF RECOMMENDATION
Staff recommends that the Commission approve Idaho Power s proposed clarifying
language to the Company s Residential Schedules 1 , and 5, with an effective date of
September 27 2010.
DECISION MEMORANDUM - 2 -SEPTEMBER 24 2010
COMMISSION DECISION
Does the Commission wish to approve Idaho Power s Tariff Advice No. 10-02 proposing
to add clarifying language to the Water Heating Section of Residential Schedules I , 3 , 4, and 5
with an effective date of September, 27, 20107
i:dmemos/ipc residential schedules ta no 10-02 (2).doc
DECISION MEMORANDUM - 3 -SEPTEMBER 24 2010