HomeMy WebLinkAbout20190510PAC to Staff 1-9.pdfY ROCKY MOUNTAIN
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REC E IVED
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Salt Lake City, Utah 84116
May 10,2019
Diane Hanian
Idaho Public Utilities Commission
472W. Washington
Boise, ID 83702-5918
diane.holt(@puc. idaho. qov (C)
RE: ID PAC-E-19-03
IPUC Audit l't Set Data Request (1-9)
Please find enclosed Rocky Mountain Power's Responses to IPUC I't Set Data Requests 1-9.
Also provided is Attachment IPUC 3.
If you have any questions, please feel free to call me at (801) 220-2963.
Sincerely,
-Js/-J. Ted Weston
Manager, Regulation
Enclosures
PAC-E-19-02 / Rocky Mountain Power
May 10,2019
IPUC l't Set Data Request 1
IPUC Data Request 1
How many customers currently take service under Schedule 135?
Response to IPUC Data Request I
As of May 1,2019, the Company has 815 customers taking service under
Schedule 135.
Recordholder: Honorino L,ora & Jarrod Martin
Sponsor: Ted Weston
PAC-E-19-02 / Rocky Mountain Power
May 10,2019
IPUC lst Set Data Request 2
IPUC Data Request 2
How many customers taking service under Schedule 135 transferred, or requested
to transfer, excess financial credit in 2018?
Response to IPUC Data Request 2
Two Schedule 135 customers transferred excess financial credits in 2018. The
Company does not keep track of requests to transfer.
Recordholder: Honorino Lora & Jarrod Martin
Sponsor: Ted Weston
PAC-E-19-02 / Rocky Mountain Power
May 10,2019
IPUC I't Set Data Request 3
IPUC Data Request 3
Please provide, in Excel format, a spreadsheet that identifies all Schedule 135
customers that generated excess kilowatt hours during any month of 2018. For
each Schedule 135 customer, please include the following information: account
number, service address, excess generation for each month, amount of financial
credit received on that account for each month, and whether the customer
transferred a credit during that month.
Response to IPUC Data Request 3
Please refer to the Schedule 135 Customer Data tab in Attachment IPUC 3.
Regarding the request for customer account numbers and addresses, the Company
objects to the request on the basis that the information is confidential customer-
specific information that the Company cannot disclose consistent with its
policy. The Company has provided unique identifiers and zip codes for the
customers in Attachment IPUC 3.
Recordholder: Honorino l-ora & Jarrod Martin
Sponsor: Ted Weston
PAC-E-19-02 / Rocky Mountain Power
May 10,2019
IPUC I't Set Data Request 4
IPUC Data Request 4
Please explain the process currently used by the Company to transfer excess
financial credit for Schedule 135 customers who request credit.
Response to IPUC Data Request 4
lt is not currently in the Company's process to transfer credits at the customer
request.
Recordholder: Honorino Lora & Jarrod Martin
Sponsor: Ted Weston
PAC-E-19-02 / Rocky Mountain Power
May 10,2019
IPUC l't Set Data Request 5
IPUC Data Request 5
How many customers takrng service under Schedule 135 have multiple meters
under different rate schedules?
Response to IPUC Data Request 5
There are25 customers taking service under Schedule 135 that have multiple
meters under different rate schedules.
Recordholder: Honorino Lora & Jarrod Martin
Sponsor: Ted Weston
PAC-E-19-02 / Rocky Mountain Power
May 10,2019
IPUC I't Set Data Request 6
IPUC Data Request 6
From January 2018 to the present, have any Schedule 135 customers transferred
excess financial credit to a meter with a rate schedule that differs from that of the
meter that generated the excess financial credit? If so, please provide, in Excel
format, a spreadsheet that identifies all Schedule 135 customers that transferred
excess financial credit to meters with different rate schedules in that time period.
For those customers, please include each customer's:
a. Account number;
b. Rate schedule for the meter that generated excess financial credit;
c. Rate schedule for each meter to which excess financial credits was
transferred; and,
d. The total number of transfers the customer made.
Response to IPUC Data Request 6
From January 2018 to the present, the Company had zero Schedule 135 customers
transfer excess financial credit to a meter with a rate schedule different than the
meter that generated the excess financial credit.
One customer requested transferring excess financial credits and was informed
that it was against Company policy. That customer filed a formal complaint with
the Commission.
Recordholder: Honorino Lora & Jarrod Martin
Sponsor: Ted Weston
PAC-E-19-02 / Rocky Mountain Power
May 10,2019
IPUC l't Set Data Request 7
IPUC Data Request 7
The Company proposes to transfer excess financial credit to meters that are
located on, or contiguous to, the premises on which the meter with excess
financial credit is located unless the customer's properties are divided by a
dedicated street, highway or other public thoroughfare, or railway. Please explain
the rationale for this exclusion.
Response to IPUC Data Request 7
The rationale is contained in the Company's Commission-approved Electric
Service Regulation Nos. 2 and 4 as detailed below. First and foremost Electric
Service Schedule No. 135 - Net metering Service "is intended primarily to offset
part or all of the Customer's own electrical requirements...installed to allow receipt
of Customer's generation connect to the Company's facilities adiacent to the
Customer's Point of Delivery."
Commission approved Electric Service Regulation No. 4 states:
SUPPLY OF SERVICE
Unless otherwise specifically provided in the electric service schedule or contract,
Company's rates are based upon the furnishing of electric service to the Customer's
oremises at a single ooint of deliverv and at a single voltage and phase
classification.
(a) Individual Customer
Each separately operated business activity and each separate building will
be considered an individual Customer for billing purposes. If several
buildings are occupied and used by one Customer in the operation of a
single and integrated business enterprise, Company will furnish electric
service for the entire group of buildings
at one point of deliverv. All such buildings shall be on the same premises.
Should the Customer reouire delivery from Comoanv throueh more than
one transformer installation. or require service from Comoanv at more
than one voltage or ohase, esch service connection ofeach voltase and
phase will be separatelv metered and billed
Section 2 Customers Use of Service states: "The Customer shall not extend his
,lrrtri, fo"iliti", for ru*i", t, othr, "urto^
Electric Service Regulation No. 2 defines Premises as "All of the real property and
apparatus employed in a single enterprise on an integral parcel of land undivided
bv a dedicated street, highwav or other public thorouehfare, or railwav."
Recordholder: Ted Weston
PAC-E-19-02 / Rocky Mountain Power
May 10,2019
IPUC I't Set Data Request 7
Sponsor: Ted Weston
IPUC Data Request 8
Aside from the definition of o'premises" as found in Electric Service Regulation
No. 2, the Company proposes that in order to be eligible for a meter-to-meter
transfer, both meters must be served by the same primary feeder and be on the
same rate schedule. What is the Company's rationale for these restrictions?
Response to IPUC Data Request 8
In Order 32846r the Commission ruled that: "The net metering tariff is for those
who wish to offset a portion of their load. Those wishing to be wholesale power
providers should look to Schedule 86 as the vehicle for that type of transaction."
The intent of net metering is not for the Company to wheel energy for net metering
customers to other facilities or premises. The Company's rates are based upon the
furnishing of electric service to the Customer's premises at a single point of delivery
and at a single voltage and phase classification. Each separately operated business
activity and each separate building is considered an individual Customer at a single
rate for billing purposes.
Conceming the requirement for aggregation to occur with the same rate schedule,
the ability to aggregate meters under different rate schedules with different rates
and cost of service creates a perverse incentive for customers to arbitrage a financial
gain with no basis in value for that excess energy to the system. For instance, the
retail rate for a customer on Schedule 1 - Residential Service is 14.9382 cents
during the summer for kilowatt-hour usage over 700 during a monthly billing
period. If that customer generated excess energy credits and were allowed to offset
another rate schedule with a much lower energy rate, such as Schedule 10 for an
irrigation pump, it would create a mismatch between the basis for the rate and
incentive to generate with no corresponding difference in value for the excess
energy to the system.
Aggregation between rate schedules also exacerbates the potential under-recovery
of fixed costs from net metering customers, does not align with the intent of net
metering as an avenue to offset a portion of a customer's usage, and diminishes the
incentive for customers to right size generation units.
Recordholder: Ted Weston
Sponsor: Ted Weston
1 Case No. PC-E-12-27
PAC-E-19-02 / Rocky Mountain Power
May 10,2019
IPUC l't Set Data Request 8
PAC-E-19-02 i Rocky Mountain Power
May 10,2019
IPUC l't Set Data Request 9
IPUC Data Request 9
Given the eligibility requirement that the meter being credited must be on, or
contiguous to the premises on which the meter with excess financial credit is
located, in what circumstances does the Company believe the additional
requirement that both meters must be served by the same primary feeder will be
invoked?
Response to IPUC Data Request 9
The Company cannot anticipate all circumstances that may occur, however much
of the Company's service territory is rural farm property where meters could be
served from different primary feeders. Idaho Power recently filed a caser to deal
with meter aggregation with irrigation customers.
The Company believes its existing rules and tariffs are clearly written to provide
service to one customer at one point of service. Net metering was never intend to
allow customers to build one generation facility and use the Company's system to
"wheel power" to aggregate meters.
ln Case No. IPC-E-12-27, parties requested meter aggregation and Idaho Power
opposed aggregation because: (1) aggregation exacerbates the potential under-
recovery of fixed costs from net metering customers; (2) aggregation does not align
with the intent of net metering as an avenue to offset usage; and (3) diminishes the
incentive for customers to right size generation units. Order No. 32925 authorized
meter aggregation on a limited basis.
On meter aggregation Rocky Mountain Power is different from Idaho Power in that
Rocky Mountain Power provides financial credits for excess generation not kWh
credits. The vast majority of fixed costs for residential customers are recovered
through variable energy rates. The Commission and staff have acknowledged net
metering shifts costs to non-participating customers. Meter aggregation increases
the potential of costs being shifted to other customers. The Company has previously
denied requests to aggregate meters and formal complaints have been filed with the
Commission. The Company does not believe meter aggregation aligns with the
intent of net metering. If the Commission determines meter aggregation is
appropriate the rules for aggregation must be easy for customers to understand and
the Company to enforce, if not some customers and developers will push the
envelope as demonstrated by IPC-E-19-15.
Recordholder: Ted Weston
Sponsor: Ted Weston
'IPC-E-I9-15.