20100830_3064.pdf

DECISION MEMORANDUM
TO:COMMISSIONER KEMPTON
CO MMISSI 0 NER SMITH
COMMISSIONER REDFORD
COMMISSION SECRETARY
LEGAL
WORKING FILE
FROM:BRYAN LANSPERY
DATE:AUGUST 30, 2010
RE:ACIFICORP TARIFF ADVICE 10-, REVISIONS TO ELECTRIC
SERVICE SCHEDULE 72
BACKGROUND
On July 14 2010, PacifiCorp ("Rocky Mountain
, "
Company ) filed several revisions
to its Schedule 72 , the Irrigation Load Control Credit Rider ("Rider ). Staff reviewed the
Company s filing and submitted a Decision Memorandum for Commission approval at the
August 6 2010 Decision Meeting. Staff has included the original Decision Memorandum as
Attachment A with this current submittal. At the Decision Meeting, the Commission expressed
concerns regarding the 'opt out' nature of the Company s proposal, noting that participants from
year to year should be notified of their participation in the upcoming irrigation season. The tariff
revisions did not contain language that expressly requires Rocky Mountain to notify past
participants of their continued involvement.
Staff notified the Company of the Commission s concern and worked to find an
appropriate way to address it. The Company stated that prior to the start of the season, it
contacts the participant twice - once by March 31 to provide an estimate of the upcoming
participation credit and a second time to have the participants sign a Load Control Service
Agreement. Due to the administrative burden, Rocky Mountain proposed streamlining the
process by removing the second step and keeping previous participants in the load curtailment
program unless they opt out prior to May 15. The initial contact with the participant would be
preserved under the Company s filing.
Upon hearing the Commission s concern, the Company revised the tariff language to
include notification of continued program participation when contacting customers of their
DECISION MEMORANDUM - 1 -AUGUST 30 2010
estimated credit. In submitting the revised Rider on August 20, the Company re-titled the
Notification of Credit' section to 'Notification of Participation and Credit', and stating:
The Company shall by March 31 of each year provide notification to customers
who have signed a Load Control Service Agreement of their scheduled program
participation in the upcoming Program Season and their estimated Load Control
Service Credit for participation during the Program Season.
Participants have until May 15 to opt out of the load control program without penalty
(stated on Sheet No. 72.3), and if they opt out after said date are subject to the terms of Special
Conditions No., which specifies reimbursement penalties based on Company costs associated
with participation in the program.
STAFF ANALYSIS
Staff has reviewed the Company s modifications and believes the changes proposed
provide sufficient notification to past participants of future participation. Staff also believes the
opt out' date of May 15 provides a suitable timeframe for planning to both the customer and
Company s for the upcoming season. Staff believes removing the requirement to sign a Load
Control Service Agreement each season as well as receiving prior notification of involvement
and estimated credit payments lightens the administrative burden, and may reduce costs
associated with the Irrigation Load Control Program. Along with the modifications discussed in
Staffs previous Decision Memorandum, the current modifications provide clarity for the
participant and the Company regarding the curtailment program. Staff therefore recommends the
Commission approve the revisions to Schedule 72 as proposed on August 20, 2010, with an
effective date of August 30, 2010.
COMMISSION DECISION
Does the Commission wish to accept the Company s revised tariff sheet for Schedule 72
with and effective date of August 20, 201 O?
i: udmemos/pac I 0- 2second -erA
DECISION MEMORANDUM - 2 -AUGUST 30, 2010
DECISION MEMORANDUM
TO:COMMISSIONER KEMPTON
COMMISSIONER SMITH
COMMISSIONER REDFORD
COMMISSION SECRETARY
LEGAL
WORKING FILE
FROM:BRYAN LANSPERY
DATE:AUGUST 6, 2010
RE:ACIFICORP TARIFF ADVICE 10-, REVISIONS TO ELECTRIC
SERVICE SCHEDULE 72.
BACKGROUND
On July 2010 PacifiCorp ("Rocky Mountain
, "
Company ) filed several revisions to
its Schedule 72, the Irrigation Load Control Credit Rider ("Rider ). The Company states the
tariff revisions are necessary to 1) align program months with the Load Control Service
Agreement; 2) provide additional time for customers to decide whether to participate in the
program; 3) remove redundant and unnecessary language; and 4) eliminate the need for annual
notices and any references to specific years. Rocky Mountain requests an effective date of
August 13 , 2010.
ST AFF ANALYSIS
Staff has reviewed the Company s filing and finds most of the modifications proposed do
not materially affect the Irrigation Load Control Program ("Program ), and simply establishes a
more concise and accurate Rider. As an example, Rocky Mountain removes references to a kWh
component to the credit received by participants on Sheets 72.1 72., and 72.5. Staff notes that
the credit is based on agreed upon levels of demand reduction, and the credit in turn has been
calculated as a fixed $IkW-Month with no energy component explicitly stated since the advent of
the Program, making references to an energy component extraneous. Staff also supports the
removal of referencing specific years in Attachment A, which specifies credit values. By doing
, Rocky Mountain would only need to modify this Sheet when credit values change rather than
prior to each season. The credits have remained the same since the 2006 season.Attachment A
Decision Memorandum
Page 1 of 2
DECISION MEMORANDUM - 1 -AUGUST 6 , 2010
Rocky Mountain also proposes two modifications regarding the Load Control Service
Agreement. The Company requests to move the customer participation notification deadline
from April 15 each season to May 15. Staff believes this is a reasonable change and provides
both the Company and participants ample time to prepare for the upcoming season.
Additionally, the Company proposes language that would keep participants in the Program for
subsequent years unless the participant expressly opts out. Participants may opt out of the
Program with no penalty if done between September 16 and May 15. Staff supports this change
and notes that this mirrors what is in place for Schedule 72A, Dispatchable Irrigation Load
Control Credit Rider Program.
Beyond items specifically listed above, Staff believes the remaining modifications to
. Schedule 72 provide clarity to the Program and are not onerous to either the Company or
participants. Staff therefore recommends the Commission approve the revisions to Schedule 72
as proposed.
COMMISSION DECISION
Does the Commission wish to accept the Company s revised tariff sheet for Schedule 72
with and effective date of August 13, 2010?
i:udmemos/pac 1 O doc
DECISION MEMORANDUM - 2 -
Attachment A
Decision Memorandum
Page 2 of 2
AUGUST 6 2010