20050711Comments.pdf

KIRA DALE PFISTERER
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 6571
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;JfILITIES COMt~HSSION
Street Address for Express Mail:
472 W. WASHINGTON
BOISE, ID 83702-5983
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF IDAHO POWER
COMPANY'S PETITION FOR AN ORDER
PROVIDING A LIMITED WAIVER OF
UTILITY CUSTOMER RELATION RULE 201.03 )
AS IT IS APPLIED TO TIME-VARIANT PRICING SERVICE.
CASE NO. IPC-05-
COMMENTS OF THE
COMMISSION STAFF
COMES NOW the Staff of the Idaho Public Utilities Commission, by and through' its
Attorney of record, Kira Dale Pfisterer Deputy Attorney General, and submits the following
comments in response to Order No. 29807.
BACKGROUND
On June 2, 2005 , Idaho Power Company filed a Petition requesting an Order providing Idaho
Power with a limited waiver of Utility Customer Relations Rule 201.03 in order to accommodate a
technology issue related to a problem with the Company s meter data translation system (MDTS).
The Company s MDTS is used to implement the time-variant pricing associated with Idaho Power
Schedules 4, 5 , and 19. Rule 201.03 requires that beginning and ending meter readings appear on
customers ' monthly billings.
STAFF COMMENTS JULY 11 2005
THE PE TITI 0 N
Currently, the Company s MDTS and billing systems do not integrate in a way that allows the
beginning and ending meter readings to be displayed on the Company s bills. According to the
Company, it would be costly and time-consuming to modify the two systems so that the beginning
and ending meter readings would print on the Company s monthly bills for customers emolled in
time-variant pricing programs.
There are three tariff rates or schedules that involve time-variant pricing that would be
affected by this proposed waiver. Under Idaho Power s Schedule 19, the energy charge varies by
whether the customer takes secondary, primary or transmission service as well as the time of day and
season. Schedule 19 applies to large commercial customers with metered demand of 1 000 kW or
more per billing period.
In addition to Schedule 19, Idaho Power has two pilot programs featuring time-variant
pricing. Both pilot programs are: (1) voluntary; (2) available only to the Company s residential
customers located in the Emmett Valley, and (3) will expire on April 1 , 2006. Under Idaho Power
Schedule 4 Energy Watch pilot program, customers will pay approximately 5.3 cents per kilowatt-
hour at any time except during those times the Company advises the customer there is an Energy
Watch in effect. Customers who opt for this Schedule will be billed 20 cents per kilowatt-hour used
during the 4-hour Energy Watch time period. Under Idaho Power s Schedule 5 Time-of-Day pilot
program, the price paid per kilowatt-hour varies between approximately 6.9 and 5.3 cents per
kilowatt-hour, depending upon the time of day electricity is used. The Schedule 4 and 5 pilots are
limited to 300 meters each. Currently the pilots have a total of 172 enrolled customers.
STAFF ANALYSIS
Initially, Staff was concerned about the lack of a beginning and ending meter reading
displayed on customer bills because it would make resolving billing disputes more difficult.
However, it is Staffs understanding that actual meter reading data can be retrieved easily from the
third-party vendor data translation system should a dispute or question arise. The information
required by Rule 201.03 will be available, but it will not be printed on bills due to technical
constraints.
In addition, Staff notes that the two residential pilot programs are of limited duration and are
only available to a limited number of customers. In general, customers will not be harmed in the
STAFF COMMENTS JULY 11 2005
short run by the lack of meter readings printed on bills since Idaho Power will provide this
information upon request.
In its Petition, the Company did not identify a specific period during which the waiver would
be in effect. Staff recommends that the waiver expire on December 31 , 2006 so that the Company
will have adequate time to evaluate its experience with time-variant pricing programs and determine
whether it can comply with Rule 201.03. Should it choose to do so, the Company could seek to
extend the waiver period or seek a permanent waiver on or before year-end 2006.
STAFF RECOMMENDATION
Staff recommends that Idaho Power s petition be approved and a limited waiver of Rule
201.03 be granted for those metering installations where time-variant pricing is facilitated by
advanced meter reading. Staff recommends that the waiver expire on December 31 , 2006.
Respectfully submitted this IlfJ- day of July 2005.
~I"" Kira Dale Pfist
Deputy Attorney General
Technical Staff:Dave Schunke
Beverly Barker
Marilyn Parker
i:umisc/comments/ipceO5.19kdpdesbabmp
STAFF COMMENTS JULY 11 2005
CERTIFICATE OF SERVICE
HEREBY CERTIFY THAT I HAVE THIS 11TH DAY OF JULY 2005
SERVED THE FOREGOING COMMENTS OF THE COMMISSION ST AFF, IN
CASE NO. IPC-05-, BY MAILING A COpy THEREOF POSTAGE PREPAID, TO
THE FOLLOWING:
BARTON L KLINE
SENIOR ATTORNEY
IDAHO POWER COMPANY
PO BOX 70
BOISE ID 83707-0070
MAGGIE BRILZ
MANAGER, RATE DESIGN
IDAHO POWER COMPANY
PO BOX 70
BOISE ID 83707-0070
SECRETARY
CERTIFICATE OF SERVICE