20070307Comments.pdf

DONOY AN E. WALKER
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 5921
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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
COMP ANY'S PETITION FOR AN EXEMPTION)
OF SPECIFIC ACCOUNTS FROM THE
COMP ANY'S RULE C PROVISIONS
REGARDING AGGREGATED METER READING.
CASE NO. IPC-O7-
COMMENTS OF THE
COMMISSION STAFF
The Staff of the Idaho Public Utilities Commission, by and through its Attorney of
record, Donovan E. Walker, Deputy Attorney General, in response to Order No. 30244, the
Notice of Application and Notice of Modified Procedure issued on February 14, 2007
respectfully submits the following comments.
BACKGROUND
On January 23 2007, Idaho Power filed a Petition requesting an exemption for specific
accounts from the Company s Rule C provisions regarding aggregated meter reading.
Idaho Power s Rule C states that where a customer has more than one delivery point or
separate meters at a single premises, that the meter readings will not be combined or aggregated
for any purpose except for determining ifthe customer s total power requirements exceed 25 000
kW. The Company requests an exemption from Rule C's aggregated meter reading provision to
STAFF COMMENTS MARCH 7, 2007
allow bills for specific large accounts to be prepared by combining the readings from multiple
meters. The Company states that this would allow it to best accommodate the electric
requirements of some of its larger customers, where multiple meters at the same premises are the
most cost-effective and optimal means to design the distribution facilities necessary to provide
the customer s requested level of service.
The Company states it currently has 13 accounts where aggregated billing would provide
the best, most cost-effective service. Those accounts are:
Amalgamated Sugar (Paul)
American Micro Systems (Pocatello)
Kinross Delamar (Murphy)
Lamb Weston (Twin Falls)
McCain Foodservice (Burley)
Micron Fab B (Nampa)
Micron Nano Fab (Boise - anticipated to be online 4/1/07)
Mountain Home Air Force Base (Mountain Home)
Irrigation Customers:
Grindstone Butte: Header 746, Pump 05s 0ge 3403 (Glenns Ferry)
Grindstone Butte: Header 744, Pump 05s 0ge 3405 (Glenns Ferry)
Farm Dev. Corp. (Sailor Creek): Header 745, Pump 05s 0ge 3404 (Glenns Ferry)
Magic Water Corp. (Buhl)
West End Proj ect (Melba)
The Company states that the customers of the above referenced accounts received a letter and a
personal contact from Idaho Power explaining the Company s intention to file this Petition
seeking an exemption from Rule C, and that no customer has objected.
The Company requests the Commission to authorize an abbreviated procedure in which it
could add additional customers to the list of those exempt from Rule C's aggregated meter
reading provisions. The Company requests that rather than filing separate petitions requesting
exemptions that the Commission authorize it to forward the customer s name, city location, and
an explanation of why aggregation is appropriate to the Commission for review. The Company
proposes that unless the Commission has an objection, that the customer would then be added to
the list of customers exempt from Rule C as it is applied to aggregated meter readings.
STAFF COMMENTS MARCH 7, 2007
STAFF ANALYSIS
Staff has reviewed the Company s filing and finds the request to provide an exception
from Rule C for these 13 specific accounts to be reasonable and appropriate. As explained in the
Company s filing, there are valid technical and/or economic reasons for using multiple meters
rather than a single meter, for these customers, and aggregating the readings from these meters
simply treats these customers as if they had a single meter. Under the current rate schedules
aggregating the readings does not impact the amount the customer is charged for the service
provided.
However, Staff is concerned that under some rate structures that might be implemented
by the Company in the future, specifically those that vary the amount of the charge for peak
demand by time of use, aggregating the readings may impact the amount the customer is billed.
In order to provide customers with the flexibility to respond to future rate changes, Staff
recommends that customers affected by this change be able to request and receive separate
billing if so desired.
Staff is comfortable with the Company using its judgment in identifying specific
customers subject to the proposed rule exemption. Therefore, Staff does not oppose the
abbreviated procedure proposed by the Company for future exemptions, provided that the
customer agrees to the change and can at any time obtain separate billing.
STAFF RECOMMENDATION
Staff recommends the Commission approve the Company s request for an exemption to
Rule C of the Company s tariff for the thirteen specific customers identified in the request. Staff
also recommends approval of the abbreviated procedure proposed by the Company for future
exemptions. Finally, Staff recommends that any customer affected by this change may request
and receive separate billing if so desired.
Respectfully submitted this ~ A day of March 2007.
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Donovan E. Walker
Deputy Attorney General
Technical Staff: Wayne Hart
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STAFF COMMENTS MARCH 7 , 2007
CERTIFICATE OF SERVICE
HEREBY CERTIFY THAT I HAVE THIS 7TH DAY OF MARCH 2007
SERVED THE FOREGOING COMMENTS OF THE COMMISSION STAFF, IN CASE
NO. IPC-07-, BY MAILING A COpy THEREOF, POSTAGE PREPAID, TO THE
FOLLOWING:
BARTON L KLINE
LISA D NORDSTROM
IDAHO POWER COMPANY
PO BOX 70
BOISE ID 83707-0070
RIC GALE
VP - PRICING & REGULATAORY
IDAHO POWER COMPANY
PO BOX 70
BOISE ID 83707-0070
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SECRETARY
CERTIFICATE OF SERVICE