20000310sw.doc

DECISION MEMORANDUM

TO: COMMISSIONER HANSEN
COMMISSIONER SMITH
COMMISSIONER KJELLANDER
MYRNA WALTERS
RON LAW
TONYA CLARK
DON HOWELL
STEPHANIE MILLER
DAVE SCHUNKE
GEORGE FINK
BEV BARKER
BILL EASTLAKE
WORKING FILE

FROM:

DATE: March 10, 2000

RE: CASE NO. IPC-E-00-1 (Idaho Power)
SCHEDULE 24—IRRIGATION TARIFF
PROPOSED REVISIONS

On December 10, 1999, Idaho Power Company (Idaho Power; Company) filed an Application with the Idaho Public Utilities Commission (Commission) for authority to revise its electric Schedule 24 tariff for irrigation service effective August 23, 2000. A copy of the Proposed Schedule 24 in legislative format is attached.
The Company contends that its filing is an effort to streamline and improve procedures, to maintain and promote customer satisfaction, and to more efficiently utilize the Company’s resources.
The following changes to Schedule 24 are proposed:
Deposit Requirements
Under the Company’s proposal the existing seasonal advance provisions of Schedule 24, which were designed to protect the Company against loss from unpaid irrigation bills, will be replaced with a revised deposit provision. The deposit provision, the Company contends, will continue to protect against losses from unpaid irrigation bills but will provide advantages to both the irrigation customers and the Company.
Idaho Power believes that irrigation customers will benefit from the change because in most cases, the proposed deposit of either the previous year’s highest month’s bill, or an estimated monthly bill, multiplied by a factor of one and one-half (1.5) will be a smaller dollar amount than a seasonal advance. Idaho Power contends that the Company will benefit from a deposit process that is more consistent and uniform with deposit provisions for its other non-residential customers. Consistent and more uniform processes will reduce training, supervision, and technical support costs. Customer-oriented innovation will also assist the Company in attaining its goals of customer service and customer satisfaction.
Idaho Power contends that another advantage of the proposed deposit requirement over the seasonal advance is its perceived ability to end a history of biennial flip-flopping between payment protection for the Company one year and no payment protection the succeeding year.
Interest on Deposits
The Company requests that the interest rate to be paid on deposits from Schedule 24 customers be the same as that paid on deposits for residential and small commercial customers. Reference Utility Customer Relations Rule 106.02.
Prepayment Option
Irrigation customers are now permitted to pay a $12.00 prepayment for their November through April customer charges with their October monthly payment. Customers choosing the prepayment option do not receive a monthly billing for the prepayment period unless there is a balance owing on the account. The Company proposes to eliminate this option. There has been a significant yearly decrease in participation and an increasing percentage of those exercising the prepayment option who are using energy in the out-of-season period.
Preferred Due Date Provision
The preferred due date provision was added to Schedule 24 when the year-round irrigation program was adopted in 1996. Under this provision, irrigation customers, particularly those with multiple accounts, may specify a single due date for all of their irrigation bills. Since the year-round irrigation program was adopted, the Company reports that it has fully implemented its Summary Billing Provision. This option allows customers to receive a summary of charges for multiple accounts in a single bill. Summary Billing, the Company reports, has become the preferred option for those customers desiring to have a single due date for multiple accounts and requires less administrative work for Company personnel. The Company requests that the preferred due date provision be eliminated for Schedule 24.
Service Connection
In order to bring more consistency to the Company’s termination and deposit requirements, once the out-of-season begins, the Company proposes that its standard termination procedures be followed for those irrigation customers who have outstanding account balances. However, irrigation customers who have had two or more late payments of $100 or more but who pay their accounts in full prior to having service disconnected, will not as a matter of routine have their service disconnected at the end of their pumping season. Rather, customers in this category will be required to pay a deposit by March 1 of the following year in order to remain connected for service during the irrigation season. The Company requests that sub-section 2 (Late Payments) under the Service Connection section of Schedule 24 be deleted.

On February 1, 2000, the Commission issued Notices of Application and Modified Procedure in Case No. IPC-E-00-1 and by Order No. 28271 suspended the Company’s proposed February 10, 2000 approval date. The deadline for filing written comments was February 24, 2000. While irrigation customers were not provided with individual notice of Idaho Power’s proposal, the Commission is apprised that a press release was issued by the Commission and direct notice was provided to Randall Budge and Anthony Yankel, individuals who have in the past represented the interests of the Idaho Irrigation Pumpers Associations. The Commission Staff was the only party to file comments (attached).
Staff recommends that the Commission approve the proposed revisions to Idaho Power’s Schedule 24 Irrigation Tariff. Staff concludes that the proposed deposit provision is superior to the existing seasonal advance for both the irrigation customers and the Company. The deposit method, Staff contends, is also more consistent with the deposit procedures for residential and commercial customers and accordingly should provide administrative benefits to the Company. Regarding the other proposed changes, Staff agrees with the Company’s reasoning. Staff summarizes the proposed changes in the following manner:

Current Tariff Provisions Proposed Tariff Provisions
Seasonal Advance – customer must advance amount equal to total of previous year’s irrigation season billings.
Deposit – customer must advance amount equal to 1.5 times the previous year’s maximum month billing. Advance due March 1; customer billings deducted from the Advance account. Deposit due March 1; customer account credited starting in September. Preferred Due Date & summary billing offered. Preferred Due Date no longer offered; Summary Billing option continues. Prepayment option for off-season at savings of $0.50/month to customer; Company only sends billing statement if power consumed. Prepayment option for off-season no longer offered. Customers will receive monthly billing statements. Advances accrue 8% interest. Deposits will accrue interest per Rule 106.02 (currently 5%).

Commission Decision
Should the proposed revisions to Idaho Power’s Schedule 24 Irrigation Service Tariff be approved? If not, what are the Commission’s thoughts?

vld/M:IPC-E-00-1_sw2

DECISION MEMORANDUM 4