20091019_2739.pdf

DECISION MEMORANDUM
TO:COMMISSIONER KEMPTON
COMMISSIONER SMITH
COMMISSIONER REDFORD
COMMISSION SECRETARY
LEGAL
WORKING FILE
FROM:BRYAN LANSPERY
DATE:OCTOBER 16, 2009
RE:IDAHO POWER COMPANY TARIFF ADVICE 09-08 REVISIONS
TO SCHEDULE 41 - STREET LIGHTING SERVICE AND REMOVAL
OF SCHEDULE 39 - STREET LIGHTING SERVICE SUPPLEMENTAL
SEASONAL OR VARIABLE ENERGY
On September 2 2009, Idaho Power Company ("Company ) filed modifications to
Schedule 41 , Street Lighting Service, while requesting the termination of Schedule 39, Street
Lighting Service Supplemental Seasonal or Variable Energy. Schedule 39 is a temporary tariff
approved by the Commission as part of the settlement in the Company s 2005 general rate case
(see Order No. 30035), and relates to vintage non-metered street lighting systems that may have
variable energy usage during the course of the year. The Company stated that such systems do
not adhere to the language in Schedule 41 , and proposed Schedule 39 as an interim measure until
(1) there is no potential for seasonal or variations in usage, (2) the street lighting service is
converted to Metered Service, or (3) May 31 , 2011 , whichever is sooner. See IPC-05-
Pengilly Direct, p. 53. The Company s current proposal would add language to Schedule 41 to
facilitate charges for unbilled energy usage on street lighting facilities, making Schedule 39
unnecessary. The Company requests an effective date of November 1 2009.
The Company s filing provides dual rationale for terminating Schedule 39 prior to the
May 31 2011 date. First, after meetings with its customers, the Company deemed the timetable
for conversion of facilities to metered service was not reasonable given customer technical
operational, and budgetary challenges. Secondly, the language of the tariff only relates to
customer-owned facilities. At the time of the original filing, it was believed that Company-
owned street lighting facilities falling under Schedule 41 did not have the capability to provide
DECISION MEMORANDUM - 1 -OCTOBER 16, 2009
variable energy. That assumption has since proven to be false. Prior to June 1 , 2004 , there were
a small number of Company-owned street lighting facilities that were constructed in such a
fashion as to provide for variable usage. The Company proposes to add language to Schedule 41
to charge for unbilled energy usage on such units. The Company further proposes language to
prevent the modification of Company-owned systems installed after June 1 , 2004 in such a way
as to allow variable energy usage. The variable energy rate is proffered to be equal to the energy
rate for Schedule 40, Unmetered General Service.
Furthermore, the Company proposes modifying language in Schedule 41 relating to
Service Area and Location. Prior to automation of the Company s billing system, changes to
facilities were documented under "Exhibit A" for each customer. These changes are now kept
electronically and provided to customers. The Company s proposed language modification
would reflect this advancement.
Staff has reviewed the Company s filing and believes it is appropriate to terminate
Schedule 39 prior to the May 31 , 2011 deadline. Staff agrees that the cost to convert affected
facilities to metered services is unwarranted. As was the case for Schedule 40 customers, the
monetary impact of a variable energy charge is de minimis from both a Company and customer
standpoint in relation to conversion costs, and relates only to a subset of customers receiving
service under this tariff (as of 2008, there are an average of 140 customers served under
Schedule 41). Staff finds that the calculation of variable energy usage used for Schedule 40
customers is appropriate for Schedule 41 customers, i., the yearly variable usage is calculated
then divided by 12 and charged on a monthly basis. It is Staff s understanding that the Company
is currently working with its customers in conducting variable energy audits for determining
unbilled usage.
Staff also finds that the additional proposed language to include Company-owned street
lighting facilities is necessary for strict adherence to the tariff. The Company has taken
sufficient steps toward minimizing the number of units that fall into this category, as units with
variable usage capability installed after June 1 , 2004 are metered and billed under the appropriate
tariff.
Staff also finds that the deletions of references to "Exhibit A" are justified and have no
adverse effects on customers, who still receive the information electronically.
DECISION MEMORANDUM - 2 -OCTOBER 16, 2009
ST AFF RECOMMENDATION
Staff recommends that the Commission accept the proposals of the Company in reference
to Schedules 39 and 41. Specifically, Staff recommends that the Commission approve the
revisions to Schedule 41 as it pertains to seasonal or variable energy usage for both Company-
owned and customer-owned street lighting systems and the removal of language referring to
Exhibit A. Should the Commission accept Staff s recommendation regarding Schedule 41 , Staff
recommends that Schedule 39 be terminated as it would be rendered moot.
COMMISSION DECISION
Does the Commission wish to accept the Company s revision to Schedule 41 as it relates
to seasonal or variable energy usage, and does it wish to terminate Schedule 39, with an effective
date of November 1 , 20097
i:udmemos/Schedule 41.doc
DECISION MEMORANDUM - 3 -OCTOBER 16, 2009