28889.doc

BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION

IN THE MATTER OF GRANTING A LIMITED EXEMPTION TO RULE 101.02 OF THE COMMISSION’S MASTER METERING RULES TO MASTER-METERED MOBILE HOME PARKS SERVED BY IDAHO POWER.
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CASE NO. IPC-E-01-36

ORDER NO. 28889
Rule 101.02 of the Commission’s Master Metering Rules for Electric Utilities states that tenants of master-metered mobile home parks must be billed by the park owner at the same rate the utility would charge if the tenant were served and billed directly by the utility. IDAPA 31.26.01.101. Regardless of whether the master-metered park is served under a residential or commercial rate, the park must charge its tenants the residential rate. However, because of new rate schedules and Bonneville Power Administration (“BPA”) billing credits the Commission must grant a limited exemption to the application of this Rule.
COMMISSION FINDINGS
Earlier this year, the Commission created a separate flat-rate schedule (Schedule 3) for master-metered parks that are taking service from Idaho Power under a residential rate. However, those parks must bill tenants under the residential tiered rate schedule (Schedule 1). Effective October 1, 2001, the Commission approved Schedule 98, which provides for a monthly billing credit to Idaho Power customers served under its residential and small farm rate schedules. The credit results from a settlement agreement between Idaho Power and BPA.
The tiered rate has complicated the process of calculating tenant bills. Requiring park owners to also include in their calculations a BPA credit that varies from month to month would introduce even more complexity into bill calculation. The Commission is concerned that billing accuracy and rule compliance will both be placed in jeopardy if strict adherence to the requirements of Rule 101.02 is mandated.
Strict adherence to Rule 101.02 also raises questions of equity. Park owners served under commercial rate schedules will not receive a BPA credit, but under Rule 101.02 must give tenants the credit. Park owners served under the residential rate are in a slightly different situation.
Park owners served under Schedule 3, the flat rate residential schedule, typically experience a revenue shortfall between what they can collect from their submetered tenants using Schedule 1, the tiered rate residential schedule. This is because tenants’ usage usually falls into the lowest rate tier ($.061652/kWh), which is lower than the flat rate charge ($.066544/kWh) paid by park owners. For example, using actual tenant consumption data supplied by one park owner and currently-approved rates, the owner would collect $325 from his tenants and pay Idaho Power $376, a $51 shortfall. If the park owner received a BPA credit but did not in turn give tenants a similar credit, the owner might break even or make a small profit, depending on the size of the credit. The Commission finds that the possibility of owners making a small profit does not override the concern that the Commission’s billing requirements with respect to mobile home park tenants be kept as simple as possible to ensure compliance with the rules as well as billing accuracy.
Based on the reasoning above the Commission finds that all master-metered mobile home parks served by Idaho Power be granted a limited exemption from Rule 101.02 with respect to the requirement that the BPA credit be included in the calculation of tenants' bills. In other words, tenants in master-metered mobile home parks would not receive the BPA credit for residential customers.
O R D E R
IT IS HEREBY ORDERED that all master-metered mobile home parks served by Idaho Power be granted a limited exemption from Rule 101.02 with respect to the requirement that the BPA credit be included in the calculation of tenants' bills.
THIS IS A FINAL ORDER. Any person interested in this Order (or in issues finally decided by this Order) or in interlocutory Orders previously issued in this Case No. IPC-E-01-36 may petition for reconsideration within twenty-one (21) days of the service date of this Order with regard to any matter decided in this Order or interlocutory Orders previously issued in this case. Within seven (7) days after any person has petitioned for reconsideration, any other person may cross-petition for reconsideration. See Idaho Code §§ 61626 and 62-619.

DONE by Order of the Idaho Public Utilities Commission at Boise, Idaho this
day of November 2001.

PAUL KJELLANDER, PRESIDENT

MARSHA H. SMITH, COMMISSIONER

DENNIS S. HANSEN, COMMISSIONER

ATTEST:

Jean D. Jewell
Commission Secretary

O:IPCE0136_jh

ORDER NO. 28889 -1-

Office of the Secretary
Service Date
November 5, 2001