20190930final_order_no_34452.pdf

Office of the Secretary
Service Date
September 30,2019
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF IDAHO POWER'S )CASE NO.IPC-E-19-17
APPLICATION FOR AUTHORITY TO )MODIFY SCHEDULE 15,DUSK TO DAWN )ORDER NO.34452
CUSTOMER LIGHTING,AND SCHEDULE )41,STREET LIGHTING SERVICE,TO )ALLOW FOR LIGHT-EMITTING DIODE )TECHNOLOGY )
On May,24 2019,Idaho Power Company ("Company"or Idaho Power")applied to
the Commission for an order allowing it to:1)modify its Schedules 15 and 41,to allow for
complete transition to Company-owned Light-Emitting Diode ("LED")lighting,and elimination
of Company-owned high-intensitydischarge ("HID")lighting in each Schedule,going forward,
effective October 1,2019,and 2)close Schedule 41 Option "B"(Company-owned,Company-
maintained streetlight facilities)effective as of September 30,2023.The Company also proposed
to eliminate "Ornamental Lighting"from Schedule 41.
On June 21,2019,the Commission issued a Notice of Application and Notice of
Modified Procedure establishing an August 21,2019 comment deadline and an August 28,2019
Company reply comment deadline.Order No.34357.Staff timely filed comments,to which the
Company did not reply.The Commission received one set of public comments,to which the
Company did reply.
With this Order we approve the Company's Application to modify Schedule 15,Dusk
to Dawn Customer Lighting,and Schedule 41,Street Lighting Service,to allow for LED
technology effective October 1,2019,and to eliminate Schedule 41 Option "B"as of September
30,2023,and to remove Schedule 41 "Ornamental Lighting."
THE APPLICATION
The Company's proposed modifications are in response to changes in the lighting
fixture industrywhere manufacturers are,and will foreseeably continue,producing more LED
fixtures and fewer HID fixtures.Application at 3.The Company stated that the proposed changes
"provide significant advantages over traditional HID lighting options.[And]...use less energy,
reduce maintenance costs ...and provide better lighting quality."Id at 3-4.The Company
estimates that if all Company-owned lighting facilities deployed under Schedule 15 and Schedule
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41 Option "A"(Company-owned,Company-maintained)were converted to LED,those changes
alone would cause 8,581 fewer Megawatt-Hours ("MWh")in annual energy consumption.Id at 4.
In four years,once all Company-owned lighting facilities have transitioned to LED,approximately
25%per year,the Company expects energy consumption attributed to these Schedules will
decrease net power supply expenses by $250,000annually,which would flow back to the customer
through the Power Cost Adjustment.Id.
The proposed modifications include:1)replacing all Company-owned HID lighting
fixtures with LED lighting fixtures,eliminating the opportunityfor new Company-owned HID
installations as of October 1,2019,and 2)discontinuing Company maintenance of customer-
owned HID streetlight facilities by eliminating Option "B"of Schedule 41,effective September
30,2023,and moving those customers to either Option "A"or Option "C"(customer-owned,
customer-maintained)of Schedule 41.Id at 4-5.The Company also proposed to eliminate
"Ornamental Lighting"from Schedule 41,which was closed in 1981 and has no remaining
customers.Id at 5.
THE COMMENTS
A.Commission Staff.
Staff filed comments recommending that the Commission approve the Company's
Application and proposed tariffs and that the Company be allowed to begin replacing Company-
owned HID lights with LED lights on October 1,2019.In its comments Staff discussed:1)
prudency,2)planned accounting treatment,and 3)customer communications.
Staff reviewed the Company's work papers for prudency and believes,even though
there will be upfront obsolescence costs associated with removing HID lighting from inventory,
these initial costs will be offset by the long-term benefits realized through reduced energy demand,
fewer technician hours required for replacement and maintenance,and smaller inventory
associated with LED lighting.Staff Comments at 3.Staff verified that the Company's Net Present
Value ("NPV")and Direct Consumer Benefit Analyses,upon which it based its decision to
transition to LED,were both reasonable and prudent.Id.Staff agreed with the Company's analysis
and position that LED lights use less than half the energy of comparable HID lights and last up to
5X longer,which should save 8,581 MWh of energy per year once all HID lights in Schedule 41
Option "B"have been converted to LED lights.Id.This energy savings should save the Company
$250,000 per year on a levelized basis.Id.Staff verified that the net benefit to the Company over
ORDER NO.34452 2
five years is $550,000,ten (10)years is $990,000,and 20 years is $2.3 million based on the
Company's NPV calculations.Id.
Staff will conduct an additional prudence evaluation for implementation,actual capital
expenditures,and cost savings when the Company seeks recovery through base rates.
It was Staff's opinion that the Company's calculations and assumptions were
reasonable,and the Company's proposed accounting treatment for adding LED lightingto plant
in service,and depreciation treatment for removing HID lighting,were proper.Id.at 4.
Staff reviewed the Company's efforts to communicate the proposed changes to affected
customers in Schedules 15 and 41 and found efforts taken by the Company were reasonable.
B.Public Comments.
The Commission received one public comment,from the City of Nampa ("City"),on
this matter.The City did not specify support or opposition to the Company's Application.The City
requested a different billingformat for Schedule 41 Option "C,"to be more in-line with Options
"A"and "B".
C.Reply Comments ofIdaho Power.
In its reply,the Company stated it could not present the billing information as sought
by the City.The Company noted:
[T]he structure for [Schedule 41]Options A and B consist of a category for
each bulb type and wattage with a count of fixtures under each category and
all fixtures 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.
COMMISSION FINDINGS AND DISCUSSION
The Company is an electric corporation and public utility.The Commission has
jurisdiction over the Company and this matter under Title 61 of Idaho Code.Having reviewed the
record,including the Company's Application,attachments,Staff and public comments,and
Company reply comments,the Commission finds the Company's proposal to modify Schedules
15 and 41 are fair,just,and reasonable and should be approvedas filed,effective October 1,2019.
Additionally,the Commission finds that the Company's request to close Schedule 41
Option "B"on September 30,2023 is fair,just,and reasonable.Because no customers remain on
ORDER NO.34452 3
Schedule 41 "Ornamental Lighting,"the Commission also finds it appropriateto close this Option
effective October 1,2019.
The Commission directs the Company to collaborate with the City regarding the
Schedule 41 Option "A"modified billing format requested by the City.We are confident that the
parties can come up with an agreeable solution for both the Company and the City.
ORDER
IT IS HEREBY ORDERED that the proposed modifications to Idaho Power's
Schedules 15 and 41,permitting the transition from HID lighting to LED lighting,are approved,
effective on October 1,2019.
IT IS FURTHER ORDERED that as of September 30,2023,Idaho Power's Schedule
41 Option "B"will close and customers will have the ability to receive service under Schedule 41
Option "A"or "C."
IT IS FURTHER ORDERED that Idaho Power's Schedule 41 "Ornamental Lighting"
is now closed and any language referencing it may be removed from the Company's tariffs.
THIS IS A FINAL ORDER.Any person interested in this Order 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.Within seven (7)days after any person has petitioned for
reconsideration,any other person may cross-petition for reconsideration.See Idaho Code §61-
626.
ORDER NO.34452 4
DONE by Order of the Idaho Public Utilities Commission at Boise,Idaho this
day of September 2019.
PAUL KJELLÁNIŠR,PRESIDENT
KRISÈNERAPER,COM ISSIONER
ERIC ANDERSON,COMMISSIONER
Diane M.Hanian
Commission Secretary
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