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HomeMy WebLinkAbout20190510PAC to Staff 1-9.pdfY ROCKY MOUNTAIN nP,",yYE*"^" REC E IVED :019 I'IAY I 0 $l llr 2 | ,,' J'?iltoJ#n?,*l I u, o *1407 W North Temple, Suite 330 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.