20200602_ch1rq.pdf

DECISION MEMORANDUM - 1 - MAY 29, 2020
DECISION MEMORANDUM

TO: COMMISSIONER KJELLANDER
COMMISSIONER RAPER
COMMISSIONER ANDERSON
COMMISSION SECRETARY
LEGAL
WORKING FILE

FROM: CHRIS HECHT

DATE: MAY 29, 2020

RE: IN THE MATTER OF IDAHO POWER’S APPLICATION FOR
AUTHORITY TO TEMPORARILY MODIFY SCHEDULE 8
ELIGIBILITY REQUIREMENTS FOR SMALL GENERAL SERVICE
ON-SITE GENERATION CUSTOMERS; CASE NO. IPC-E-20-23

THE APPLICATION
On May 6, 2020, Idaho Power submitted an Application to temporarily modify Schedule
8, Small General Service On-site Generation (“Schedule 8”) to allow customers whose usage
would otherwise require them to move to Schedule 9, Large General Service (“Schedule 9”) to
voluntarily remain under Schedule 8 through December 31, 2020. The Company’s Application
requests an effective date of June 5, 2020 and that the change be processed as a tariff advice, or
alternatively, through Modified Procedure.

STAFF REVIEW
Schedule 8 applies to small general service on-site generation customers whose usage is
2,000 kilowatt-hours (kWh) or less in ten or more of the most recent twelve months. Schedule 8
customers whose usage is more than 2,000 kWh in three of the previous twelve months are
required to move to Schedule 9, in conjunction with Schedule 84, Customer Energy Production
Net Metering Service (“Schedule 84”).
An important difference between Schedule 8 and Schedule 9/Schedule 84 is that
Schedule 8 allows customers to use a single meter that measures net usage, while Schedule 9/
Schedule 84 customers are required to bear the expense of installing two meters: one meter that
measures energy usage and a second meter that measures generation. Schedule 9/Schedule 84

DECISION MEMORANDUM - 2 - MAY 29, 2020
customers are unable to revert back to Schedule 8 because the two-meter configuration does not
allow the energy generated by the customer on-site to offset the customer’s usage, so the
customer’s usage will not be low enough to qualify for Schedule 8 again. In addition, Schedule
9 customers pay a demand charge, but Schedule 8 customers do not. Furthermore, the two meter
configuration required by Schedule 84 does not permit Schedule 9 customers to use the energy
they generate to offset their demand.
The Company’s proposed modification allows Schedule 8 customers whose usage would
otherwise require them to take service under Schedule 9/Schedule 84, and thereby incur the
expense of reconfiguring their system to comply with the dual-meter requirement and be subject
to a demand charge, to voluntarily remain on Schedule 8. Staff believes the Company’s
proposed temporary modification is reasonable because it will protect customers from
unnecessary expense until this issue is fully addressed by the Commission, and therefore
recommends that the Commission approve it.
However, the Company’s proposed tariff states that this modification should be
“Effective until 12/31/2020...” Staff believes it is unlikely that this issue will be resolved in a
separate docket before the end of this year. Therefore, Staff recommends that the tariff language
be updated to indicate that the temporary modification will remain in effect “until an order is
issued that addresses metering configuration for Schedule 84 customers” (Application at 3).
Staff therefore proposes that the change to Schedule 8 be stated as: “Effective until a
final order is issued that addresses metering configuration for Schedule 84 customers, and any
appeal period has passed or the order has been upheld on appeal, existing Schedule 8 customers
who no longer meet the energy usage requirement of Schedule 8 that ‘energy usage is 2,000
kWh, or less, per Billing Period for ten or more Billing Periods during the most recent 12
consecutive Billing Periods[,]’ can elect Schedule 8.”
Staff believes this language would apply to Schedule 8 customers who have recently
exceeded the Schedule 8 energy usage requirement but have not installed the dual-meter
configuration required by Schedule 84.
This language would not preclude a resolution earlier than December 31, 2020, and it
would also prevent the Company, Staff, Parties, and the Commission from revisiting this issue
before it is addressed in the future case the Company states it intends to file.
Staff agrees with the Company that this change can be properly addressed as a tariff
advice to provide a speedy resolution for customers who may be financially impacted by a delay.

DECISION MEMORANDUM - 3 - MAY 29, 2020
STAFF RECOMMENDATION
Staff recommends that the Commission process this case through a tariff advice and
approve the Company’s request to provide this temporary modification to Schedule 8 effective
June 5, 2020. Staff recommends the Commission order the Company to file conforming tariffs
with the updated language proposed by Staff above.

COMMISSION DECISION
Does the Commission wish to:
1. Process this case as a tariff advice?
2. Approve the Company’s request for a temporary modification to Schedule 8
effective June 5, 2020 so that customers who would otherwise be required to
move to Schedule 9/Schedule 84 may voluntarily remain on Schedule 8?
3. Direct the Company to file a conforming Schedule 8 tariff that allows customers
to voluntarily remain on Schedule 8 until an order addressing metering
configuration for Schedule 84 customers becomes final?

_/S/ Chris Hecht_____________
Chris Hecht

Udmemos/IPC-E-20-23 Decision Memo