20190828Reply Comments.pdf

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An IDACORP Company
LISA D. NORDSTROM
Lead Counsel
[e-mail]
RECEIVED
2019 eU0 28 PH lr: 32
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August 28,2019
VIA HAND DELIVERY
Diane Hanian, Secretary
ldaho Public Utilities Commission
47 2 W esl Wash in gton Street
Boise, ldaho 83702
Re Case No. IPC-E-19-17
Authority to Modify Schedule 15, Dusk to Dawn Customer Lighting, and
Schedule 41, Street Lighting Service, to Allow for Light Emitting Diode
Technology - ldaho Power Company's Reply Comments
Dear Ms. Hanian
Enclosed forfiling in the above matter are an originaland seven (7) copies of ldaho
Power Company's Reply Comments.
Very truly yours,
Lisa D. Nordstrom
LDN:kkt
Enclosures
P.O. Box 70 (83707)
1221 W. ldaho 5t.
Boise, lD 83702
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LISA D. NORDSTROM (lSB No. 5733)
ldaho Power Company
1221West ldaho Street (83702)
P.O. Box 70
Boise, ldaho 83707
Telephone: [phone]
Facsimile: [phone]
I nord strom @ ida hopower. com
Attorney for ldaho Power Company
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
RECEIVED
2019 AUG 28 Ptt lr: 32
tr1.1 1!*1'j PUtsLlCr;ri ii ii:r-; COi\{MISSION
IN THE MATTER OF IDAHO POWER'S
APPLICATION FOR AUTHORITY TO
MODIFY SCHEDULE 15, DUSK TO DAWN
CUSTOMER LIGHT!NG, AND SCHEDULE
41, STREET LIGHTING SERVICE, TO
ALLOW FOR LIGHT-EMITTING DIODE
TECHNOLOGY
CASE NO. IPC-E-19-17
IDAHO POWER COMPANY'S
REPLY COMMENTS
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ldaho Power Company ("ldaho Power" or "Company") respectfully submits these
Reply Comments in response to the Comments filed by the ldaho Public Utilities
Commission ("Commission") Staff and the City of Nampa ("City") on August21,2019.
ldaho Power acknowledges and appreciates both parties' review of the Company's
request in this case.
I. BACKGROUND
Idaho Power has requested approval to (1) modify tariff Schedule 15, Dusk to
Dawn Customer Lighting ("Schedule 15") and Schedule 41, Street Lighting Service
IDAHO POWER COMPANY'S REPLY COMMENTS. 1
("Schedule 41") to allow for light-emitting diode ("LED') technology effective October 1,
2019, and (2) close Option "B" of Schedule 41, customer-owned, ldaho Power-maintained
systems effective September 30, 2023.
Schedule 41 is applicable to electric service provided for lighting of public streets,
public alleys, public grounds, and thoroughfares to improve visibility for drivers, as well
as to illuminate outdoor pedestrian walkways. Schedule 41 provides three service options
for street lighting customers.
. Option A provides for ldaho Power-owned and ldaho Power-maintained street
lighting systems. Street lighting systems under this option are not metered and
customers pay monthly lamp charges based on their choice of standard wattage
high pressure sodium vapor lamps.
. Option B provides for customer-owned, ldaho Power-maintained street lighting
systems. Option B was closed to new service in 2012 as a part of ldaho Power's
last general rate case, Case No. IPC-E-11-08. All new customer-owned lighting
systems installed after January 1,2012, are required to take service under Option
C.
. Option C provides a service option for customers choosing to own their lighting
system(s). Option C allows customers to install any lighting wattage or technology
and to provide their own maintenance without being charged for ldaho Power-
provided maintenance.
II. IDAHO POWER'S REPLY
ln these Reply Comments, ldaho Power will respond to the City's proposed
changes to the bill format for customers taking service under Option C of Schedule 41.
On page 1 of its comments, the City requested that "ldaho Power provide 41C billing
IDAHO POWER COMPANY'S REPLY COMMENTS - 2
information" for Option C of Schedule 41 in the same billformat as Options A and B where
the following information is detailed on the bill: (1) the wattage per street light, (2) the
number of street lights at that wattage, (3) the price of each individual street light, and (4)
the sum total.
Unfortunately, because the underlying structure in ldaho Power's billing system for
Options A and B is different than for Option C, ldaho Power is unable to present the
information on bills for Option C in the same manner as Options A and B. The structure
for Options A and B consists of a category for each bulb type and wattage with a count of
fixtures under each category and allfixtures in each category are charged the same fixed
rate. Conversely, the structure for Option C consists of a single entry for each fixture
where the wattage information and burn-hours are stored independently under each
fixture to subsequently calculate the number of kilowatt-hours per fixture for billing. Even
though the fixtures may have the same wattages under Option C, the number of burn-
hours varies for some fixtures, and therefore, cannot be combined by wattage category.
Subsequent to reviewing comments submitted by the City, the Company met with
the City to discuss options for providing it with the information it has requested. The
Company has committed to provide a report to the City with the requested information on
an annual basis or upon request. This report would be similar in nature to the Distribution
Facilities lnvestment Report that is provided to customers who pay a monthly facilities
charge to the Company for Company-owned facilities beyond the point of delivery under
Rule M.
ilt. coNcLustoN
The Company appreciates the opportunity to respond to comments filed in this
case and respectfully requests that the Commission issue an order approving the
IDAHO POWER COMPANY'S REPLY COMMENTS - 3
modification of tariff Schedule 15 and Schedule 41 to allow for the replacement of all High
lntensity Discharge ("HlD") Company-owned lighting systems with LED light fixtures and
to discontinue maintenance of customer-owned HID lighting systems by transitioning
customers from Option "8" of Schedule 41 to either Option "C" or Option "A" by September
30,2023.
DATED at Boise, ldaho, this 28th day of August 2019.
p
LISA D
Attorney for ldaho Power Company
IDAHO POWER COMPANY'S REPLY COMMENTS.4
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 28th day of August 2019 I served a true and correct
copy of IDAHO POWER COMPANY'S REPLY COMMENTS upon the following named
parties by the method indicated below, and addressed to the following:
Gommission Staff
Dayn Hardie
Deputy Attorney General
ldaho Public Utilities Commission
47 2 W est Wash i ngton (83702)
P.O. Box 83720
Boise, ldaho 83720-007 4
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City of Nampa Public Works Dept.
Larry Hoobery
Lead Electrician
City of Nampa Streets/Traffic Division
106 W. Railroad
Nampa, ldaho 83651
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0 ^rruTExecutive Assistant
IDAHO POWER COMPANY'S REPLY COMMENTS - 5