20231121_IPCE2329_dh.pdf

DECISION MEMORANDUM
TO:COMMISSIONER ANDERSON
COMMISSIONER HAMMOND
COMMISSIONER LODGE
COMMISSION SECRETARY
COMMISSION STAFF
LEGAL
FROM:MICHAEL ELDRED
DAYN HARDIE
DATE:NOVEMBER 21,2023
SUBJECT:IN THE MATTER OF IDAHO POWER COMPANY'S REQUESTFOR
EXEMPTION FROM THE COMPANY'S RULE C PROVISIONS
REGARDING AGGREGATING METER READING;
CASE NO.IPC-E-23-29
BACKGROUND
On November 1,2023,Idaho Power Company ("Company")requested to add the Lamb
Weston manufacturing facility in American Falls to the list of customers exempt from Rule C's
aggregated meter reading provisions.
The Company's Rule C states that where a customer has more than one deliverypoint or
separate meters at a single premises,that the meter readings will not be combined or aggregated
for any purpose except for determining if the customer's total power requirements exceed 20,000
kW.
In Case No.IPC-E-07-02,Order No.30274,the Commission granted the Company an
exemption from Rule C's aggregated meter reading provision to allow bills for specific large
accounts to be prepared by combining the readings from multiplemeters.Each of the 13
customers identified in that case involved situations where having multiplemeters at the same
premises was the most cost-effective and optimal means of providing and metering service.
Order No.30274 also authorized a streamlined regulatory procedure for handling future
situations where an exemption to Rule C was merited and sought by the Company.Instead of
requiring the Company to file a petition for each additional exemption,the Company was
DECISION MEMORANDUM -1 -NOVEMBER 21,2023
authorized to provide the Commission with information supporting its decision that an
exemption was merited.Unless the Commission objected to a proposed exemption,the affected
customer would then be added to the list of customers exempt from Rule C provisions.
STAFF ANALYSIS
Staff reviewed the Company's request to add Lamb Weston to the Rule C exemption list
and has no objection to the Company's request.However,to ensure the Commission has an
updated list of all customers under the exemption,Staff recommends the Company provide a list
of Rule C exemption customers to the Commission througha compliance filing.
The Lamb Weston facility is currentlya Schedule 19 customer but is expanding the
facility and is expected to soon be above the 20 MW load threshold requiring a Special Contract.
A Special Contract for Lamb Weston was approvedin Case No.IPC-E-23-18,Order No.35929.
When Lamb Weston exceeds the 20 MW threshold and becomes a Special Contract Customer,
the Rule C exemption will no longer be required because Rule C's aggregated meter reading
provision will not apply.The configuration that is most economic for Lamb Weston's expansion
plans is to service the customer using three feeders and three primary metering packages.This
economic justification behind the Company's request is consistent with the justification provided
in Case No.IPC-E-07-02 where the original 13 customers were approved to be included on the
Rule C exemption list.
The Company in this request stated it would submit an updated list of Rule C exemption
customers to the Commission.Staff agrees and recommends the Company provide the list in a
compliance filing to the Commission within seven days of the Commission's decision.
RECOMMENDATION
Staff recommends the Commission accept the Company's request to add Lamb Weston to
the list of Rule C exemptions and require the Company to file a compliance filing with an
updated list of Rule C exemption Customers within seven days of the Commission's decision.
DECISION MEMORANDUM -2 -NOVEMBER 21,2023
COMMISSION DECISION
Does the Commission wish to accept the Company's request to add Lamb Weston to the
list of Rule C exemptions and require the Company to file a Compliance Filing with an updated
list of Rule C exemption Customers within seven days of the Commission decision?
Michael Eldred
Udmemos/IPC-E-23-29 Decision Memo
DECISION MEMORANDUM -3 -NOVEMBER 21,2023