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Home My WebLink About20161219PAC to Staff 8-35.pdfROCKY MOUNTAIN POWER A D!VlSION OF ?ACIFICOAP December 19, 2016 Jean Jewell Idaho Public Utilities Commission 4 72 W. Washington Boise, ID 83702-5918 RE: ID PAC-E-16-13 IPUC 2nd Set Data Request (8-35) 201 South Main, Suite 2300 Salt Lake City. Utah 84111 Please find enclosed Rocky Mountain Power's Responses to IPUC Data Requests 8-35. IPUC 23 and IPUC 28 will be provided under separate cover. Also provided are Attachments IPUC 8, 9, 12, 16 and 35. If you have any questions, please feel free to call me at (801) 220-2963. Sincerely, J. Ted Weston Manager, Regulation P AC-E-16-13 I Rocky Mountain Power December 19, 2016 IPUC 2nd Set Data Request 8 IPUC Data Request 8 From the following Section addressed in Regulation 12, please provide one representative example from each line extension type using actual customer installation information. If no actual examples are available, please provide representative hypothetical examples. For each example, please explain in detail the differences in methodology and show any cost difference from the current policy to the proposed approach identified in the Company filing. Further, if there is any affect to the existing ratepayers, quantify the cost difference and show how it would affect the customer class. Please provide workpapers in Excel format with formulae intact. a. Section 2 -Residential Extensions 1. Standard Residential 1. Overhead Service 2. Underground Service 11. Remote Service 1. Overhead Service 2. Underground Service 111. Three Phase Residential Service 1v. Transformation Facilities v. Underground Extensions Response to IPUC Data Request 8 Line extension allowances are capital investments that may increase rate base. Changes in allowances may change the growth in rate base. If rate base grows faster than the revenue necessary to support the growth in ratebase, then the long term impact is an increase in rates. The allowances proposed are targeted to be "revenue neutral", meaning the grov\1:h in rate base due to the allowance comes with adequate new revenue so as not to have an impact on rates. Due to the time limitations to query the system for projects reflecting each scenario, the costs given in Attachment IPUC 8 are representative hypothetical examples. Recordholder: Rob Stewart Sponsor: Rob Stewart PAC-E-16-13 I Rocky Mountain Power December 19, 2016 IPUC 2nd Set Data Request 9 IPUC Data Request 9 From the following Section addressed in Regulation 12, please provide one representative example from each line extension type using actual customer installation information. If no actual examples are available, please provide representative hypothetical examples. For each example, please explain in detail the differences in methodology and show any cost difference from the current policy to the proposed approach identified in the Company filing. Further, if there is any affect to the existing ratepayers, quantify the cost difference and show how it would affect the customer class. Please provide workpapers in Excel format with formulae intact. a. Section 3 -Non-Residential Extensions i. Extension Allowances -Delivery at 46,000 Volts and above 11. Extension Allowances Delivery at less than 46,000 Volts 1. Less than 1,000 kV A 2. 1,000 kV A or Greater 3. Additional Capacity m. Additional Customers, Advances and Refunds 1v. Reduction in Contract Capacity or Demand v. Underground Extensions v1. Other Requirements v11. Street Lighting Response to IPUC Data Request 9 The line extension proposal was designed to be revenue neutral to have no effect on existing ratepayers (see response to IPUC 8). There is no difference in methodology, other than that associated with the change in the allowance from $90/kW to nine months of estimated average monthly usage. See Attachment IPUC 9 for a comparison of the two allowances. a.i. Extension Allowances Delivery at 46,000 Volts and above. There is no change between the existing and the proposed tariffs. The allowance is limited to the metering (meter, current transformers and voltage transformers). a.ii. Extension Allowances Delivery at less than 46,000 Volts. Attachment IPUC 9 contains representative hypothetical examples comparing the allowances and facilities charges for a non-residential customer taking three phase secondary delivery. The same comparison works for 1,000 kV A or Greater by using a larger load and the appropriate rate schedule revenues. P AC-E-16-13 I Rocky Mountain Power December 19, 2016 IPUC 2nd Set Data Request 9 a.iii through a.vii. There is no change or impact on allowances, advances or contract minimum billings. Recordholder: Rob Stewart Sponsor: Rob Stewart P AC-E-16-13 I Rocky Mountain Power December 19, 2016 IPUC 2nd Set Data Request 10 IPUC Data Request 10 From the following Section addressed in Regulation 12, please provide one representative example from each line extension type using actual customer installation information. If no actual examples are available, please provide representative hypothetical examples. For each example, please explain in detail the differences in methodology and show any cost difference from the current policy to the proposed approach identified in the Company filing. Further, if there is any affect to the existing ratepayers, quantify the cost difference and show how it would affect the customer class. Please provide workpapers in Excel format with formulae intact. a. Section 4 -Extensions to Non-Residential and Residential Planned Developments 1. General 11. Allowances and Advances 111. Refunds 1v. Underground Extensions Response to IPUC Data Request 10 The line extension proposal was designed to be revenue neutral so there would be no effect on existing ratepayers (see response to IPUC 8). The additional wording in section 4(a) is addressed in the response to IPUC 7. The change in the wording for refund calculations and underground extensions is for clarification only, with no change in practice. The difference between the existing and proposed tariffs is in the allowance for residential subdivisions. Please see Attachment IPUC 8 for residential comparisons. The existing tariff grants an allowance of transformer, meter and service to residential customers in general, an allowance of the transformers to the developer of residential subdivisions where secondary is installed to the lot line, and an allowance of the meter and service to the home builder on a lot in such a subdivision. The proposed tariff grants an allowance of $1550 to residential customers, an allowance of $1000 to the developer of residential subdivisions where secondary is installed to the lot line, and an allowance of $550 to the home builder on a lot in such a subdivision. Please see Attachment IPUC 16 for the breakout of the $1550 into $1000 and $550, and also the response to IPUC 5. P AC-E-16-13 I Rocky Mountain Power December 19, 2016 IPUC 2nd Set Data Request 10 Recordholder: Rob Stewart Sponsor: Rob Stewart PAC-E-16-13 I Rocky Mountain Power December 19, 2016 IPUC 2nd Set Data Request 11 IPUC Data Request 11 From the following Section addressed in Regulation 12, please provide one representative example from each line extension type using actual customer installation information. If no actual examples are available, please provide representative hypothetical examples. For each example, please explain in detail the differences in methodology and show any cost difference from the current policy to the proposed approach identified in the Company filing. Further, if there is any affect to the existing ratepayers, quantify the cost difference and show how it would affect the customer class. Please provide work.papers in Excel format with formulae intact. a. Section 5 -Extension Exceptions 1. Applicant Built Extensions 11. Duplicate Service Facilities 111. Emergency Service rv. Highly Fluctuating Loads v. Temporary Service v1. Line Capacity in Excess of that Required Response to IPUC Data Request 11 The proposed line extension was designed to have no effect on existing ratepayers (see response to IPUC 8). There are no changes in methodology. The only cost difference between the existing and proposed tariffs is in the allowance. If there is an allowance it is indicated below. a.1. Applicant Built Extensions: The estimating for an applicant built line depends on whether the applicant is residential, non-residential or a developer. The allowance calculations are as given in responses to IPUC 8, 9 and 10, respectively. The additional factors for an applicant built line are given in the response to IPUC 25. a.u. Duplicate Service Facilities: There is no change between the existing and the proposed tariffs. There is no allowance. The customer pays the costs for the duplicate line, whatever those costs may be. a.m. Emergency Service: The only change between the existing and the proposed tariffs is in the allowance. The only manner in which Emergency Service differs from standard non-residential is the contract minimum billing does not end after five years, the same as remote service. PAC-E-16-13 I Rocky Mountain Power December 19, 2016 IPUC 2nd Set Data Request 11 a.iv. Highly Fluctuating Loads: The only change between the existing and the proposed tariffs is in the allowance. The manner in which Highly Fluctuating Loads differ from standard non-residential is 1) the contract minimum billing does not end after five years, and 2) the customer pays for the costs of additional equipment needed to prevent unacceptable voltage fluctuations for other customers, or other power quality issues. a.v. Temporary Service. There is no change between the existing and the proposed tariffs. There is no allowance. a.vi. Line Capacity in Excess of that Required. There is no change between the existing and the proposed tariffs. This section states that Company ''betterment" is not included in customer costs, or contract minimum billings. Recordholder: Rob Stewart Sponsor: Rob Stewart PAC-E-16-13 I Rocky Mountain Power December 19, 2016 IPUC 2nd Set Data Request 12 IPUC Data Request 12 From the following Section addressed in Regulation 12, please provide one representative example from each line extension type using actual customer installation information. If no actual examples are available, please provide representative hypothetical examples. For each example, please explain in detail the differences in methodology and show any cost difference from the current policy to the proposed approach identified in the Company filing. Further, ifthere is any affect to the existing ratepayers, quantify the cost difference and show how it would affect the customer class. Please provide workpapers in Excel format with formulae intact. a. Section 6-Relocation or Replacement of Facilities 1. Relocation of Facilities ii. Local Governments Response to IPUC Data Request 12 There is no change in the tariff, so there would not be a difference between the current tariff and the proposed tariff. a.1. Two examples of overhead to underground conversions are provided in Attachment IPUC 12. One example is for a city and one is for a farm. a.11. The Company could not locate a local government conversion where other than the city was impacted, so there is not an example of where an underground district was required. The data is not available in Excel format, rather are screen captures from Company's construction management system. Recordholder: Rob Stewart Sponsor: Rob Stewart P AC-E-16-13 I Rocky Mountain Power December 19, 2016 IPUC 2nd Set Data Request 13 IPUC Data Request 13 For each of the examples provided by the Company for Staff Production Request Nos. 8 through 12, please provide the sources of information used to determine the cost estimate amounts. Response to IPUC Data Request 13 For the representative hypothetical examples the cost data was taken from a simplified form which is updated semi-annually from the Company's construction management system with an average of the most common transformers, conductors, poles and meters. For the examples using actual jobs, the costs were determined using the Company's construction management system. Recordholder: Rob Stewart Sponsor: Rob Stewart PAC-E-16-13 I Rocky Mountain Power December 19, 2016 IPUC 2nd Set Data Request 14 IPUC Data Request 14 Please provide copies of all line extension policies currently in effect for each of the state jurisdictions in which Rocky Mountain Power/PacifiCorp serves. Response to IPUC Data Request 14 The online links to the Utah and Wyoming line extension tariffs were provided in the response to IPUC The line extension tariffs for the Pacific Power/PacifiCorp states are found online at the following addresses: California, Rule 15: Oregon, Rule 13: Washington, Rule 14: !~"~'-'-..!c'.-2'.!2:.~~~~::.~~~.::L'±!~~'L!'L~~~ Recordholder: Rob Stewart Sponsor: Rob Stewart P AC-E-16-13 I Rocky Mountain Power December 19, 2016 IPUC 2nd Set Data Request 15 IPUC Data Request 15 On page 2 of Robert Stewart's testimony, he states the proposed changes to the line extension allowances are designed to be revenue neutral. Please explain what is meant by the term "revenue neutral." Response to IPUC Data Request 15 Line extension allowances are capital investments thus are investments in rate base. Changes in allowances change the growth in rate base. If rate base grows faster than the revenue necessary to support the growth in rate base, then the long term impact is an increase in rates. The proposed allowances are targeted to be "revenue neutral", meaning the growth in rate base due to the allowance comes with adequate new customer revenue so as not to have an impact on rates. Recordholder: Rob Stewart Sponsor: Rob Stewart P AC-E-16-13 I Rocky Mountain Power December 19, 2016 IPUC 2nd Set Data Request 16 IPUC Data Request 16 Please provide an explanation of the method, the calculation, and the sources of data the Company used to determine the allowances for residential, non residential, non-residential and residential planned developments. Please provide work papers in Excel format with formulae intact Response to IPUC Data Request 16 Please refer to Mr. Stewart's testimony on pages 11, 12, and 21 as well as Exhibit No. 4 provided with the Company's filing. Please refer to Attachment IPUC 16 for the Company's work papers. Recordholder: Robert Meredith Sponsor: Rob Stewart PAC-E-16-13 /Rocky Mountain Power December 19, 2016 IPUC 2nct Set Data Request 17 IPUC Data Request 17 For each of the allowance types in Staff Production Request No. 16 above, please explain and demonstrate how the allowance reflects the embedded cost in base rates. Please provide workpapers in Excel format with formulae intact. Response to IPUC Data Request 17 Please refer to the Company's response to IPUC 16. The calculations which the Company performed to support its proposed residential and non-residential line extension allowances utilize the percentage of line extension-related costs from the unit costs from the 2010 Cost of Service Study, which was the last general rate case under which base rates were set, and apply those percentages to actual revenue in 2015. Recordholder: Robert Meredith Sponsor: Rob Stewart PAC-E-16-13 I Rocky Mountain Power December 19, 2016 IPUC 2nd Set Data Request 18 IPUC Data Request 18 Please provide workpapers with formulae intact used by the Company to establish the amounts proposed for the distribution and transmission facilities charges as specified on Sheet 300.3 of the proposed tariff. Response to IPUC Data Request 18 Please see the attachment provided with the response to IPUC 1. Recordholder: Rob Stewart Sponsor: Rob Stewart PAC-E-16-13 I Rocky Mountain Power December 19, 2016 IPUC 2nd Set Data Request 19 IPUC Data Request 19 Please explain how engineering costs are billed to new customers? Are the costs calculated for each specific job? Are the costs sho\\ln separately on the customer's bill, or are they included in a general overhead? If the costs are included in a general overhead, what is the general overhead rate and how much of the general overhead rate do engineering costs represent? Response to IPUC Data Request 19 Engineering costs are included in the line extension estimate. They are calculated as a percentage of the construction man hour labor costs. The percentage is updated annually. For 2016 the cost percentage is 21.6%. This estimating labor cost is then increased by the 12.75% capital surcharge and added into the job. The Company bills a customer for a line extension by presenting them a line extension contract which lists the line extension allowance and customer advance. No itemization is presented. Recordholder: Rob Stewart Sponsor: Rob Stewart PAC-E-16-13 I Rocky Mountain Power December 19, 2016 IPUC 2nd Set Data Request 20 IPUC Data Request 20 Please describe what constitutes a large, complex or speculative line extension as discussed on Sheet 12R.1 of the proposed tariff? Response to IPUC Data Request 20 A large line extension is any load over one megawatt in demand. Complex is for requests that are likely to require significant system additions or improvements. Some examples are substation upgrades, main feeder reconstruction, and construction involving multiple feeders in order to shift load. Speculative is where there is not reasonable assurance that the applicant will sign the line extension contract and become a customer. Please see the response to IPUC 7 for discussion on reasonable assurance. Recordholder: Rob Stewart Sponsor: Rob Stewart PAC-E-16-13 I Rocky Mountain Power December 19, 2016 IPUC 2nd Set Data Request 21 IPUC Data Request 21 Are customers billed for line extension costs based on the estimated costs or actual costs, and how is the cost reflected in journal entries? Please explain. Response to IPUC Data Request 21 Rocky Mountain Power uses both estimated costs and actual costs depending on the size of the load and the cost of the job. The general guideline is that requests for loads of one megawatt and up are billed on actual, and those of less than one megawatt are billed based on the estimate. Customer contributions of $50,000 or less are booked directly to the project as CIAC. Customer contributions greater than $50,000 are initially booked to a liability account and then a journal entry is made to the project as CIAC on a monthly basis in amounts equal to the actual expenses for that month. After completion of the project, any funds remaining in the liability account are either journal vouchered to the project (if it's a project that is based on estimate) or refunded to the customer (if it's a project based on actual costs). Recordholder: Rob Stewart Sponsor: Rob Stewart PAC-E-16-13 / Rocky Mountain Power December 19, 2016 IPUC 2nd Set Data Request 22 IPUC Data Request 22 Does the Company compile and record the actual construction costs once construction has been completed? Please explain. Response to IPUC Data Request 22 Yes, actual construction costs are recorded in SAP (the Company's accounting system). Only if the project is billed on actuals (see the response to IPUC 21) is the customer advance reconciled to actuals. Recordholder: Rob Stewart Sponsor: Rob Stewart P AC-E-16-13 I Rocky Mountain Power December 19, 2016 IPUC 2nd Set Data Request 24 IPUC Data Request 24 Do facilities charges change (increase or decrease) for a line extension if additional customers connect? Please explain. Response to IPUC Data Request 24 A customer's facilities charge only changes when there is a refund, i.e. when additional customers connect. The customer paying the refund becomes responsible for the facilities charge on that portion of their advance, just as they are responsible for the facilities charges on the rest of their advance. The facilities charges of the customer receiving the refund are reduced by the facilities charges associated with the refund (see regulation 12, section 3(c)). Recordholder: Rob Stewart Sponsor: Rob Stewart PAC-E-16-13 / Rocky Mountain Power December 19, 2016 IPUC 2nd Set Data Request 25 IPUC Data Request 25 How are costs for design, specifications, material standards, and inspections as discussed in Section 5(a)(3) on sheet 12R.1 l estimated? Does an applicant pay these costs if the Company builds the line instead? If so, is the applicant billed explicitly or through an overhead charge? Response to IPUC Data Request 25 When a customer requests an Applicant Built Line Extension, the Company designs the extension using the same procedures and tools they would use if the Company were building the line. The estimate for design costs includes the hours logged by an estimator to develop the detailed design, and a small number of hours for the estimator to work with the applicant during construction. If an engineering study is needed, the estimate for design costs also includes the hours logged by an engineer in performing the study. The specifications and material standards are provided electronically, which cost is included in the engineering overhead added to the logged hours of the estimator and engineer. The inspection estimate is based on the anticipated construction hours in the designed job. For Company built lines the design costs, which are the engineering and estimating costs, are included in the line extension estimate and are included as a percent of the cost of the line extension estimate (see the response to IPUC 19). For Company built lines the inspection of construction work is done by the job foreman, who is part of the work crew, therefore this cost is included in the line extension cost estimate. The applicant is not provided access to the specifications and material standards, so the applicant is not billed for these items. Recordholder: Rob Stewart Sponsor: Rob Stewart PAC-E-16-13 / Rocky Mountain Power December 19, 2016 IPUC 2nd Set Data Request 26 IPUC Data Request 26 Under Section 5( e )(3) on sheet 12R.13, how long would a customer for temporary service be required to pay a contract minimum billing? Please explain. Response to IPUC Data Request 26 A customer pays the facilities charge on their temporary service during the time that they take temporary service. Sometimes a customer requests temporary service for construction which requires a line extension that will become part of their permanent extension. The permanent portion of the extension with its facility charge becomes part of the contract for permanent service. The facilities charge associated with the portion of the extension that is removed, the "temporary" portion, ends when that portion is disconnected. Recordholder: Rob Stewart Sponsor: Rob Stewart PAC-E-16-13 I Rocky Mountain Power December 19, 2016 IPUC 2nd Set Data Request 27 IPUC Data Request 27 Does a customer under Section 5(e) on sheet 12R.13, which requests temporary service from an existing line extension pay the same amount for sharing the line as a permanent customer would pay? Please explain. Response to IPUC Data Request 27 Yes, the Company collects an advance from any customer connecting to a line under contract for refunds, and refunds that advance to the original customer. As stated in Section 5(e)(3) "The [temporary] Customer is also responsible for ... any advance required for sharing previous Extensions; ... ". Recordholder: Rob Stewart Sponsor: Rob Stewart PAC-E-16-13 I Rocky Mountain Power December 19, 2016 IPUC 2nd Set Data Request 29 IPUC Data Request 29 If the Company's proposed line extension policy is adopted and implemented, how would the Company's annual revenue requirement be affected? Please explain in detail the effect to each customer class served by the Company. Provide supporting information to quantify the effect. Response to IPUC Data Request 29 The annual revenue requirement will only be impacted to the extent that the new customer revenues do not offset the additional capital investment made to serve that customer. As noted in prior responses the line extension was designed to be revenue requirement neutral. The revenue requirement from the Company's proposed changes would only vary inasmuch as the Company spends less or more in allowances than it would of otherwise under the Company's current tariffed line extension allowance policies. It is uncertain what this revenue requirement impact would be over time, since the Company does not know the level of future development, new revenues collected, nor the service characteristics for any future development that may occur in its service territory. Recordholder: Robert Meredith Sponsor: Rob Stewart P AC-E-16-13 I Rocky Mountain Power December 19, 2016 IPUC 2nd Set Data Request 30 IPUC Data Request 30 Please provide a list of the refunds issued for line extensions for each of the past five years. For each refund type, show the amount of the refund, the refund recipient type (i.e. residential, farm, commercial, industrial, other), and the cumulative amount refunded to each recipient in relation to the total amount the recipient paid for his line extension. Response to IPUC Data Request 30 The name of the customer who paid a refundable advance and received refunds from addition customer( s) attaching has been replaced with a letter in the following table. line Extension Refunds 2012 through 2016 Customer's Line Refunds to Customer from I additional applicants i l Customer Customer Type A Residential B Irrigation C Residential Developer D I Residential Apartments E Residential F Residential G Com. Developer Recordholder: Rob Stewart Sponsor: Rob Stewart Extension Advance Vear Amount Vear Amount I 2010 $ 15,649.00 2014 $ 2,009.00 2012 $100,767.00 2016 $19,085.00 2012 $149,920.00 I 2012 $10,513.00 ' $ 2,570.00 2015 2011 $ 11,492.00 2014 $ 653.00 ~ 10,075.00 2015 $ 1,612.00 ' 12,589.00 2015 $ 1,868.00 45,607.00 2012 $ 6,309.00 PAC-E-16-13 / Rocky Mountain Power December 19, 2016 IPUC 2nd Set Data Request 31 IPUC Data Request 31 Please describe in detail the Company's process for tracking refunds of a refundable advance. Please provide the methodology used by the Company to calculate facilities charges for line extension customers. Response to IPUC Data Request 31 On the construction system, when a refundable line is built, a flag associated with each facilities point is set, which expires when the refund period ends. When the estimator designs a job which connects to a line with a refundable advance the flag alerts them that a refund is due upon connection of new applicant. Refunds are tracked in the Company's customer billing system. The following items are entered into the Company's billing system: the advance the original customer pays; the number of potential refunds; the start date (in service date of the line) and ending date (five years after the start date); and its associated with the customer's account number, contract number and the work request number. When a refund is issued the amount of the refund is deducted from the recorded advance amount and the potential refunds is decreased by one. Methodology used to calculate Facilities Charges: The Company designs the job using the Company's construction management system, which produces the job cost based on the design. This is the job cost. The Company then deducts any betterment or other costs that are not the customer's cost responsibility. This gives the adjusted job cost. The available allowance is applied to this adjusted cost. If the allowance does not cover the adjusted job cost, the remainder is the customer advance. This advance combined with any advance the customer owes as a refund to an existing customer is used for the facility charge calculation on their advance. The monthly Facilities Charges equals (the Allowance x 1.67%) plus (the customer advance x 0.67%). Recordholder: Rob Stewart Sponsor: Rob Stewart PAC-E-16-13 I Rocky Mountain Power December 19, 2016 IPUC 2nd Set Data Request 32 IPUC Data Request 32 Please describe how the Company determines if a line extension is to be considered remote service. Response to IPUC Data Request 32 Remote Service applies to line extensions in excess of one-half mile in length (Regulation 2, definition Remote Service). Recordholder: Rob Stewart Sponsor: Rob Stewart PAC-E-16-13 I Rocky Mountain Power December 19, 2016 IPUC 2nd Set Data Request 33 IPUC Data Request 33 By year for CY 2011-2015, please provide the following for remote service line extensions in Idaho: (a) number ofremote service line extensions constructed; (b) average length of line extensions; ( c) total (gross) cost of line extensions; ( d) total amount of allowances applied towards line extension costs. Response to IPUC Data Request 33 Details of remote line extensions constructed 2011 through 2015 are given in the following table. Year (a) Remote J (b) Length of extensions ' line extension constructed 2011 0 - 2012 1 ! 5280 ft 2013 0 - i 2014 l 0 - 2015 1 3300 ft Recordholder: Rob Stewart Sponsor: Rob Stewart (c) Cost of I ( d) Allowance line extension I -- $112,917 ' $12,150 -- -- $52,047 $11,700 P AC-E-16-13 I Rocky Mountain Power December 19, 2016 IPUC 2nd Set Data Request 34 IPUC Data Request 34 How does the Company monitor population density in remote service areas to ensure customers are no longer considered "remote service" when the population density reaches one person per half mile? Response to IPUC Data Request 34 There are very few of these extensions (see response to request no. 33). The Company relies on customers to notify the Company when they believe they are no longer remote. The Company will then investigate to determine if the remote contract should be canceled. Recordholder: Rob Stewart Sponsor: Rob Stewart PAC-E-16-13 I Rocky Mountain Power December 19, 2016 IPUC 2nd Set Data Request 35 IPUC Data Request 35 Please provide a sample of a residential remote service minimum billing contract. Response to IPUC Data Request 35 Please see Attachment IPUC 35 Residential Remote. Recordholder: Rob Stewart Sponsor: Rob Stewart