20091207Decision Memo.pdf

DECISION MEMORAUM
TO:COMMISSIONER KEMPTON
COMMISSIONER SMITH
COMMISSIONER REDFORD
COMMISSION SECRETARY
LEGAL
WORKNG FILE
::~L ..~_ /)~ - iò
FROM:BRYAN LANSPERY
DATE:APRIL 24, 2009
RE: COMPLIANCE FILING - REVISION TO RULE E.
On April 10,2009, Idaho Power Company ("Company") fied its revision to Rule E,
Master Metering Stadards. Specifically, the Company added language to section 2b that states
sub-metered tenants will be biled by the park operator at the rate specified under Schedule 3 -
Master Metered Mobile Home Park Residential Service. The Company contends that the
revision to the taiff sheet is necessar to comport with Commission Order No. 30754.
Staf has reviewed the Commission Order to confirm the Company's contention.
According to the Commission Decision on the issue, a flat rate for Schedule 3 was approved, and
that "(t)his is also the rate that master-metered customers should use when biling their tenants."
Order No. 30754, page 10.
Rule 101.02 of the Idaho Public Utilities Commission Master Metering Rules, IDAPA
31.26.01, states that "( m )obile home parks sub-metered by the park operator must charge each of
their tenants the same rate for electric service that a residential customer of the utilty serving the
park would charge the tenant if the tenant were directly metered and biled by the utility."
Therefore without a waiver the Commssion Order is in conflct with the Master Metering Rules.
By virte of the language in Commission Order No. 30754, Staff believes that the Commission
implicitly determned that biling tenants under the thee-tier residential rate strcture would be
impracticable, thus waranting a waiver to the curent rues regarding master meterig.
Under the proposed language, the park operators will bil their tenants at the rate outlined
under Schedule 3. Staff notes that for residential master-metered mobile home parks, this is the
same rate Idaho Power Company charges the park operator. For master-metered parks biled
DECISION MEMORADUM - 1 -APRIL 24, 2009
under commercial rate Schedules 7 or 9, the tenants will be biled under the flat rate defied in
Schedule 3. Sta believes that grantig a waiver and approving the Company's proposed
modification to Schedule 3 complies with Commssion Order No. 30754.
STAFF RECOMMENDATION
Staff believes that the revision to Rule E is necessar, and that the Company's proposal
captues the spirit of the Commission Order. Sta recommends that the Commission grant a
waiver to the Master Metering Rule 101.02, and accept the modification of Idalio Power
Company's Rule E, to be effective on Commission approval.
COMMSSION DECISION
Does the Commission wish to grant a waiver to Rule 101.02 of its Master Metering Rules
for Electric Utilities, and accept the revision to Rule E- Master Metering Standards proposed by
Idaho Power Company?
~
i: dec memo Rule E.doc
DECISION MEMORADUM - 2-APRIL 24, 2009