Loading...
HomeMy WebLinkAbout20190821Comments.pdfDAYN HARDIE DEPUTY ATTORNEY GENERAL IDAHO PUBLIC UTILITIES COMMISSION PO BOX 83720 BOISE, IDAHO 83720.0074 (208) 334-0312 IDAHO BAR NO. 9917 IN THE MATTER OF IDAHO POWER'S APPLICATION FOR AUTHORITY TO MODIFY SCHEDULE 15, DUSK TO DAWN CUSTOMER LIGHTING, AND SCHEDULE 41, STREET LIGHTING SERVICE, TO ALLOW FOR LIGHT.EMITTING DIODE TECHNOLOGY REC E IVED ?ilI9 AU0 2l Plt l: 0l , ,,l,r''ill#li,?*18*no* Street Address for Express Mail: 472 W. WASHINGTON BOISE, IDAHO 83702-5918 Attorney for the Commission Staff BEFORB THE IDAHO PUBLIC UTILITIES COMMISSION ) ) ) ) ) ) ) ) CASE NO. IPC.E-I9-I7 COMMENTS OF THE COMMISSION STAFF STAFF OF the Idaho Public Utilities Commission, by and through its Attorney of record, Dayn Hardie, Deputy Attorney General, submits the following comments. BACKGROUND On May 24,20l9,Idaho Power Company ("Company") filed an Application requesting the Commission's authority to (l) modify Schedde 15, Dusk To Dawn Customer Lighting, and Schedule 41, Street Lighting Service, to allow for light-emitting diode ("LED") technology, eliminate the option for new installations of Company-owned High Intensity Discharge ("HID")I street lights and area lights going forward effective October 1,2019, and (2) close Option "B" of Schedule 41, Customer-owned, Idaho Power-maintained systems as of September 30, 2023, moving those customers to either Schedule 41 Option "A", which is Company-owned, Company-maintained streetlight facilities, or Schedule 41 Option "C", which is Customer- ' HID lighting refers to either high pressure sodium or metal halide light fixtures. App. at 3 1STAFF COMMENTS AUGUST 2I,2OI9 owned, Customer-maintained streetlight facilities.2 Application at I and 4. The proposed modifications to Schedules 15 and 4l will allow the Company to transition from HID to LED Company-owned lighting over a period of four (4) years, beginning October 1,2019. Id. at 4. Additionally, the Company proposes to permanently eliminate Schedule 41's "Ornamental Lighting"3 option. Id. The proposed modifications to Schedules 15 and 41 will not affect the current rates set in either Schedule. Id. at 5. Proposed tariff changes are shown in Attachments I and2 of the Application. As of March2}lg, there were 6,389 customers in Idaho taking service under Schedule 15;82 customers taking service under Schedule 41A;42 customers taking service under Schedule 4lB; and 631 customers taking service under Schedule 41C. Schedule 41 customers are primarily cities. Id. at3. The Company currently performs maintenance on approximately 9,742 fixtures owned by roughly 42 customers in Idaho under Option "B" of Schedule 41. Id. STAFF REVIEW Through its review, Staff believes that a decision to transition to LED lighting as reflected in the Application is reasonable. Staff reviewed the prudency of the Company's proposal and recommends that the Company be allowed to begin replacing Company-owned HID lighting systems starting October l, 2019 per the Application. Staff also reviewed the planned accounting treatment reflected in the Company's cost/benefit analysis, proposed changes to Schedules I 5 and 4l , and communications provided to customers which Staff found all to be reasonable. Prudency Anal),sis The Company provided two (2) types of analysis to support the cost-effectiveness of their proposal. The first analysis shows the net present value revenue requirement difference between the business-as-usual case of continuing to use HID lighting and transitioning to LED lighting. 2 Option "B" of Schedule 41 is for customer-owned, Company-maintained streetlight facilities. Application at2. lt was closed to new customers as of January 1,2012, and currently has 42 customers. Id. Option "B" Schedule 41 customers are primarily cities. Id. at3. 3 Omamental Lighting was closed to new service after October 3 I , l98l , and through attrition, no customers remain under the offering. Id. at 5. 2STAFF COMMENTS AUGUST 21,2019 The analysis showed a net benefit of $550 thousand through the first five (5) years, $990 thousand through the first ten (10) years, and $2.3 million over 20-years. The second analysis shows the direct customer benefit of reduced energy cost by transitioning to more efficient LED lighting which is estimated to be about $250 thousand per year on a levelized basis. Staff reviewed the Company's workpapers and believes its analysis is reasonable and the transition to LED lighting is prudent. LEDs have a longer lifespan compared to HID lighting which directly reduces maintenance cost. LEDs can last on average 100,000 hours or more. Based on expected Company usage, LEDs will typically last 24.6 years compared to an average of 4.9 years for HID bulbs currently in use. The extended life of LED lighting directly benefits customers by reducing the number of times a service technician is dispatched to replace a failed lighting element over time. The long lifespan will also contribute to about a30o/o reduction in the value of inventory for maintenance and replacement purposes once fully transitioned to LEDs. The reduction in inventory will also come as a result of reducing the number of catalog items held in inventory from 59 to 1 1. Initially, the Company may incur some obsolescence costs due to the transition to LEDs. In order to remove HID lighting from inventory the Company will work with suppliers and resellers to determine what unused inventory remaining after the change-out can be returned for credit. Any unreturned or remaining materials will be sent to the Investment Recovery department to sell to the open market. If the Company is unable to sell the remaining HID lighting, the components will be recycled or properly disposed of as needed. Customers will directly benefit from more efficient LED lighting by saving $250,000 per year in net power cost. On a comparable lighting basis (i.e. lumens), LEDs use less than half the energy of HID lights. This will reduce the amount of energy needed to serve Schedule 15 and 41 customers by 8,851 MWh per year. Although there is less energy required, LEDs provide more uniform light coverage, with less glare and fewer dark spots, which improves lighting visibility. Although Staff recommends that the Company move forward with its proposed conversion based on information provided in this filing, a subsequent prudence determination of the Company's implementation, actual capital expenditures and cost savings will be conducted when the Company seeks recovery through base rates. STAFF COMMENTS AUGUST 21,2079aJ Accounting Treatment Staff reviewed the Company's financial assertions related to this proposed LED conversion, including the estimated annual revenue requirement of transitioning to LED lighting fixtures, the estimated annual revenue requirement for Schedule 15 and 41 customers, the estimated decrease in lighting inventory, and the estimated decrease in maintenance costs. Staff also reviewed the Company's estimates for adding and disposing of plant in service, as well as its depreciation and tax expenses. Staff believes the Company's calculations and assumptions are reasonable, and the Company's proposed accounting treatment for adding the LED lighting fixtures to plant in service, and depreciating and removing the HID lighting fixtures appear to be proper. As stated previously, the Company's actual accounting transactions and expenses will be subject to review as part of the Company's next general rate case. Customer Communication Prior to filing its Application, Idaho Power identified 46 cities who take service under Schedule 41, as the ones most impacted by the changes being proposed by the Company.a Idaho Power met with city personnel from each of the cities identified to gather feedback. Some city personnel shared lessons they had learned from their city's experience of having converted customer-owned street lights to LED technology. Most of the customer feedback the cities had received was in regard to the color temperature of the LED lights and the need for a shields to be installed on the LED lights to prevent glare. Idaho Power took the feedback into consideration when preparing its Application for the proposed LED change out plan. Idaho Power created a webpage to explain the Company's proposal.s It was made available the same day as the filing. In addition to general information about the proposal, the webpage also includes a Company phone number for customers who would like to speak with an energy advisor, as well as a link to the Application, IPUC website, and "Frequently Asked Questions". The frequently asked questions addressed the following: 1) why Idaho Power was requesting the change; 2) whether street light or area light account holders had the option to a Of the 46 cities, 42 cities constitute all Schedule 4lB customers. As of May 24,2019 Schedule 4lA customers totaled 82, 418 customers totaled 42, and 4 I C customers totaled 63 I . 5 The webpage can be accessed at rvu,rv.idahoporver.corn/l-ljD. STAFF COMMENTS AUGUST 2I,2OI94 decline the changeover to LED lighting; 3) when the changeover process would commence; 4) the appearance of LED fixtures; 5) the brightness of LED lights compared to existing HID light f,txtures; 6) the color temperature selected for the LED fixture; and 7) what impact the change would have on a customer's electric bill. Schedule 41 (Street Lighting Service) Either by phone or in person, Idaho Power Company representatives personally contacted all customers who are served under Option "A" or Option "B" of Schedule 4l to inform them of the Company's filing and the charges they would be seeing. Additionally, a letter was mailed to inform customers of the filing, how they would be impacted, and how to submit comments to the Commission. The outreach process began around June 3 and ended on July 12,2019. If Idaho Power's proposal is approved, the Company will again mail letters and have Company representatives personally contact the impacted customers, informing them of the Commission's decision and discuss the implementation plan. Schedule l5 (Dusk to Dawn Customer Lighting) A bill insert was mailed to all Schedule 15 customers informing them of Idaho Power's filing and proposal. The first mailing began on June 24 and ended on July 9,2019. The bill insert-contained a brief explanation of the Company's proposal, the web address to the Commission website, the web address to Idaho Power's dedicated LED project webpage, and a Company phone number for customers to call if they have questions. Additionally, at the time the Company performs the LED replacement, a door hanger will be left at the premise informing the customer that the lighting was replaced. Customer Notification Customers were given until August2l,2Ul9, to file comments. As of August20,2019, no customer comments were filed. 5STAFF COMMENTS AUGUST 21,2019 STAFF RECOMMENDATION Staff recommends the Commission approve the Company's request to modifu Schedule 15, Dusk to Dawn Customer Lighting, and Schedule 41, Street Lighting Service as shown in Attachments I and 2 of the Application. Respecttully submitted this ZIF Aay of August 2019 Dayn Hardie Deputy Attorney General Technical Staff: Richard Keller Bentley Erdwurm Brad Long Curtis Thaden i:umisc/comments/ipce I 9. I Tdhrkblbecwh comments 6STAFF COMMENTS AUGUST 2I,2OI9 ldaho Power Company Twelfth Revised Sheet No. 15-2 Cancels l.P.U.C. No. 29. Tariff No. 101 Eleventh Revised Sheet No. 15-2 SCHEDULE 15 DUSK TO DAWN CUSTOMER LIGHTING (Continued) NEW FACILITIES Where facilities of the Company are not presently available for a lamp installation which will provide satisfactory lighting service for the Customer's Premises, the Company may install overhead or underground secondary service facilities, including secondary conductor, poles, anchors, etc., a distance not to exceed 300 feet to supply the desired service, all in accordance with the charges specified below. MONTHLY CHARGE Effective October 1,2019, High Pressure Sodium Vapor lighting systems are not available for new installation. The Monthly Charge is the sum of the following charges, and may also include charges as set forth in Schedule 55 (Power Cost Adjustment), Schedule 91 (Energy Efficiency Rider), and Schedule 95 (Adjustment for Municipal Franchise Fees). 1. Monthly Per Unit Charqe on existinq facilities: AREA LIGHTING Hiqh Pressure Sodium Vapor LED Equivalent Base Rate Watts 100 20a 400 Averaqe Lumens 8,5s0 19,800 45,000 Watt Ranqe Lumen Ranqe30-40 3,600-4,80070-85 7,200-9,600175-200 18,000-24,000 FLOOD LIGHTING LED Equivalent Watt Ranoe 70-85 120-150 Lumen Ranoe 8,100-10,800 18,000-24,000 $ 9.50 $1 1.34 $15.36 Base Rate $13.58 $16 02 Base Rate $14.71 $23.38 Hioh Pressure Sodium VaporWatts Averaqe Lumens200 19,800400 45,000 Metal HalideWatts Averaqe Lumens400 28,8001,000 88,000 LED Equivalent Watt Range 120-150 250-300 Lumen Ranqe 18,000-24,000 32,000-38,000 2. For New Facilities lnstalled Before June 1. 2004: The Monthly Charge for New Facilities installed prior to June 1,2004, will continue to be assessed a monthly facilities charge in accordance with the changes specified in Schedule 66. 3. For New Facilities lnstalled On or After June '1, 2004: The non-refundable charge for New Facilities to be installed, such as underground service, overhead secondary conductor, poles, anchors, etc., shall be equal to the work order cost. PAYMENT The monthly bill for service supplied hereunder is payable upon receipt, and becomes past due 15 days from the date on which rendered. IDAHO lssued per Order No. Effective - October 1,2A19 lssued by IDAHO POWER COMPANY Timothy E. Tatum, Vice President, Regulatory Affairs 1221 West ldaho Street, Boise, ldaho r- za 6po- tr B " 5.EZU<O n.L+$ X (;-, a..l! 6:Y;<u65 ldaho Power Company l.P.U.C. No. 29. Tariff No. 101 Third Revised Sheet No.41-1 Cancels Second Revised Sheet No. 41-1 SCHEDULE 41 STREET LIGHTING SERVICE AVAILABILITY Service under this schedule is available throughout the Company's service area within the State of ldaho where street lighting wires and fixtures can be installed on Customer-provided street lighting facilities or installed on the Company's existing distribution facilities. APPLICABILITY Service under this schedule is applicable to service requested or installed by Customers for the lighting of public streets, public alleys, public grounds, and thoroughfares. Street lighting lamps will be energized each night from dusk until dawn. SERVICE LOCATION AND PERIOD Street lighting facility locations, type of unit and lamp sizes, as changed from time to time by written request of the Customer and agreed to by the Company, shall be provided for Customers receiving service under Options A and B of this schedule. The in-service date for each street lighting facility shall also be maintained. The minimum service period for any Company-owned street lighting facility is 10 years. The Company, upon written notification from the Customer, will remove a Company-owned street lighting facility: 1. At no cost to the Customer, if such facility has been in service for no less than the minimum service period. The Company will not grant a request from the Customer for reinstallation of street lighting service at the same location for a minimum period of two years from the date of removal. 2. Upon payment to the Company of the removal cost, if such facility has been in service for less than the minimum service period. SERVICE OPTIONS "A" - ldaho Power-Owned. ldaho Power-Maintained Svstem - Effective October 1. 2019. hioh pressure sodium vaoor liqhtinq svstems are not available for new installation. The facilities required for supplying service, including fixture, lamp, control relay, mast arm for mounting on an existing utility pole, and energy for the operation thereof, are supplied, installed, owned and maintained by the Company. All necessary repairs and maintenance work, including group lamp replacement and glassware cleaning, will be performed by the Company during the regularly scheduled working hours of the Company on the Company's schedule. lndividual lamps will be replaced on burnout as soon as reasonably possible after notification by the Customer and subject to the Company's operating schedules and requirements. The Company has two standard high pressure sodium vapor street lighting fixture options, drop-glass or cutoff (shielded lighting). For each initial high pressure sodium vapor lighting fixture installation, the Customer is required to state, in writing, a fixture preference. A maintenance-related replacement of a current high pressure sodium vapor fixture will be made with a similar type of drop-glass or cut-off fixture as the one being replaced unless written notification has been received from the Customer requesting a change in fixture types. IDAHO lssued per Order No. Effective - October 1,2019 lssued by IDAHO POWER COMPANY Timothy E. Tatum, Vice President, Regulatory Affairs 1221 West ldaho Street, Boise, ldaho t-- \O Cl.vlf -;o'l : 60ZU6F H.;5-EZU<H siuFP=d\<Uii3 ldaho Power Company Tenth Revised Sheet No. 41-2 Cancels l.P.U.C. No. 29, Tariff No. 101 Ninth Revised Sheet No. 41-2 SCHEDULE 41 STREET LIGHTING SERVICE (Continued) SERVICE OPTIONS (Continued) "A" - ldaho Power-Owned, ldaho Power-Maintained Svstem (Continued) Company-owned lighting systems installed on or after June 1, 2004 shall not be constructed, operated, or modified in such a way as to allow for the potential or actual variation in energy usage, such as through, but not limited to, the use of wired outlets or useable plug-ins. Company-owned systems installed prior to June 1 , 2004 that are constructed, operated, or modified in such a way as to allow for the potential or actual variation in energy usage may have the estimated annual variations in energy usage charged the Non-Metered Service - Variable Energy Charge until the potential for variations in energy usage has been eliminated. Repair, modification or alteration of these facilities is not permitted. Accelerated Replacement of Existino Fixtures ln the event a Customer requests the Company perform an accelerated replacement of existing fixtures with the cut-off fixture, the following charges will apply: 1. The designed cost estimate which includes labor, time, and mileage costs for the removal of the existing street lighting fixtures. The total charges identified in 1 and 2 above must be paid prior to the beginning of the fixture replacement and are non-refundable. The accelerated replacement will be performed by the Company during the regularly scheduled working hours of the Company and on the Company's schedule. Dark Skv Liqhtinq for Hiqh Pressure Sodium Vapor ln the event a Customer requests the Company perform an alteration of existing cut-off fixtures to become dark sky lighting compliant by replacing the existing drop-lens with a dark sky lighting compliant flat-lens, the following charges will apply: 1. The designed cost estimate which includes labor, time, and mileage costs for the alteration of the existing street lighting fixtures. 2. $23.00 per fixture altered for dark sky lighting. The total charges identified in 1 and 2 above must be paid prior to the beginning of the fixture alteration and are non-refundable. The fixture alteration to become dark sky lighting compliant will be performed by the Company during the regularly scheduled working hours of the Company and on the Company's schedule. f- \O(H o\o6l- N -: rrJ I 9^zn Eg 9.r Eo.EZJ<H srtFrHSD<(J7)o IDAHO lssued per Order No. Effective - October 1,2019 lssued by IDAHO POWER COMPANY Timothy E. Tatum, Vice President, Regulatory Affairs 1221 West ldaho Street, Boise, ldaho 2. $132.00 per fixture removed from service. ldaho Power Company Tenth Revised Sheet No. 41-3 Cancels l.P.U.C. No. 29, Tariff No. 101 Ninth Revised Sheet No. 41-3 SCHEDULE 41 STREET LIGHTING SERVICE (Continued) SERVICE OPTIONS (Continued) "A" - ldaho Power-Owned. ldaho Power-Maintained Svstem (Continued) LED Shield LED Equivalent ln the event a Customer requests the Company install a shield on an LED fixture, the Customer will be responsible for the material cost of the equipment, as well as the design cost estimate which includes labor, time, and mileage costs for the alteration of the existing LED fixture. Monthlv Charqes The monthly charges are as follows, and may also include charges as set forth in Schedule 55 (Power Cost Adjustment), Schedule 91 (Energy Efficiency Rider), and Schedule 95 (Adjustment for Municipal Franchise Fees). Lamp Charqes, per lamp (41A) Hioh Pressure Sodium VaporWatts Averaqe Lumens70 5,540100 8,5s0200 19,800250 24,754400 45,000 Non-Metered Service - Variable Enerqy Energy Charge, per kWh Pole Charoes 7.360i For Company-owned poles installed after October 5, 1964 required to be used for street lighting only: Charqe Wood pole, per pole $1.81 Steel pole, per pole $7.18 Facilities Charoes Customers assessed a monthly facilities charge prior to June 1, 2004 will continue to be assessed a monthly facilities charge in accordance with the charges specified in Schedule 66. Pavment The monthly bill rendered for service supplied hereunder is payable upon receipt, and becomes past due 15 days from the date on which rendered. Watt Ranqe 30-40 30-40 70-85 1 15-140 175-200 Lumen Ranoe 3,600-4,800 3,600-4,800 7,200-9,600 10,800-14,400 18,000-24,000 Base Rate $11.39 $10.86 $14.55 $15.83 $18.0s IDAHO lssued per Order No. Effective - October 1,2019 lssued by IDAHO POWER COMPANY Timothy E. Tatum, Vice President, Regulatory Affairs 1221 West ldaho Street, Boise, ldaho f-. \O tiO\v 6l F C.l o' q.r g d4'^ZodseO- E* o-Ftr o 56S ,4 IJ: E gESi0#3 ldaho Power Company Fourteenth Revised Sheet No.41-4 Cancels l.P.U.C. No.29.Tariff No. 101 Thirteenth Sheet No.414 SCHEDULE 41 STREET LIGHTING SERVICE (Continued) SERVICE OPTIONS (Continued) "8" - Customer-Owned, ldaho Power-Maintained Svstem - No New Service and Effective September 30, 2023. Option B is closed to service. The Customer's lighting system, including posts or standards, fixtures, initial installation of lamps and underground cables with suitable terminals for connection to the Company's distribution system, is installed and owned by the Customer and maintained by ldaho Power. Customer-owned lighting systems receiving maintenance under Option B must have ldaho Power standard wattage high pressure sodrum vapor lamps installed in all street lighting fixtures. Customer-owned systems installed on or after June 1, 2004 which are constructed, operated, or modified in such a way as to allow for the potential or actual variation in energy usage, such as through, but not limited to, the use of wired outlets or useable plug-ins, are required to be metered in order to record actual energy usage. Customer-owned systems installed prior to June 1 , 2004 that are constructed, operated, or modified in such a way as to allow for the potential or actual variation in energy usage may have the estimated annual variations in energy usage charged the Non-Metered Service - Variable Energy Charge until the street lighting system is converted to Metered Service, or until the potential for variations in energy usage has been eliminated, whichever is sooner. Energv and Maintenance Service Energy and Maintenance Service includes operation of the system, energy, lamp renewals, cleaning of glassware, and replacement of defective photocells which are standard to the Company-owned street light units. Service does not include the labor or material cost of replacing cables, standards, broken glassware or fixtures, painting, or refinishing of metal poles. lndividual lamps will be replaced on burnout as soon as reasonably possible after notification by the Customer and subject to the Company's operating schedules and requirements. Monthlv Charqes The monthly charges are as follows, and may also include charges as set forth in Schedule 55 (Power Cost Adjustment), Schedule 91 (Energy Efficiency Rider), and Schedule 95 (Adjustment for Municipal Franchise Fees). IDAHO lssued per Order No. Effective - October 1,2019 lssued by IDAHO POWER COMPANY Timothy E. Tatum, Vice President, Regulatory Affairs 1221 West ldaho Street, Boise, ldaho t-- \O o.*..-\ a n, ^EU-^-qZo 6 F tr o oe.EZO<3 s2hK -(EUoo<U(,O ldaho Power Company l.P.U.C. No. 29 Tariff No. 101 Ninth Revised Sheet No. 41-5 Cancels Eiqhth Revised Sheet No. 41-5 SCHEDULE 41 STREET LIGHTING SERVICE (Continued) SERVICE OPTIONS {Continued) "8" - Customer-Owned, ldaho Power-Maintained Svstem - No New Service (Continued) Non-Metered Service, per lamp (418) Non-Metered Service - Variable Enerov Energy Charge, per kWh Metered Service, per lamp (418M) Standard High Pressure Sodium Vapor Enerqv and Maintenance Charoes: 70 Watt 100 Watt 200 Watt 250 Watt 400 Watt Standard High Pressure Sodium Vapor Maintenance Charqes: 70 Watt 100 Watt 200 Watt 250 Watt 400 Watt Service Charge, per meter Energy Charge, per kWh Average Lumens 5,450 8,550 19,800 24,754 45,000 7.3600 $3.36 5.0531 Base Rate $3.07 $3.43 $4.96 $6.11 $8.64 $1.36 $1.26 $1.25 $1.36 $1.36 Pavment The monthly bill rendered for service supplied hereunder is payable upon receipt, and becomes past due 15 days from the date on which rendered. "C" - Customer-Owned. Customer-Maintained Svstem The Customer's lighting system, including posts or standards, fixtures, initial installation of lamps and underground cables with suitable terminals for connection to the Company's distribution system, is installed, owned, and maintained by the Customer. The Customer is responsible for notifying the Company of any changes or additions to the lighting equipment or loads being served under Option C - Non-Metered Service. Failure to notify the Company of such changes or additions will result in the termination of non-metered service under Option C and the requirement that service be provided under Option C - Metered Service. IDAHO lssued per Order No. Effective - October 1,2019 lssued by IDAHO POWER COMPANY Timothy E. Tatum, Vice President, Regulatory Affairs 1221 West ldaho Street, Boise, ldaho r-- \o o\a{- r).r,rr o oo'l : boza 6s 9; Eo, -c4U\H s?tKt5#3 ldaho Power Company Ninth Revised Sheet No. 41-6 Cancels l.P.U.C. No. 29. Tariff No. 101 Eiohth Revised Sheet No. 41-6 SCHEDULE 41 STREET LIGHTI NG SERVICE (Continued) "C" - Customer-Owned, Customer-Maintained Svstem (Continued) All new Customer-owned lighting systems installed outside of Subdivisions on or after January 1 , 2012 are required to be melered in order to record actual energy usage. Customer-owned systems installed prior to June 1 , 2004 that are constructed, operated, or modified in such a way as to allow for the potential or actual variation in energy usage may have the estimated annual variations in energy usage charged the Non-Metered Service - Energy Charge until the street lighting system is converted to Metered Seryice, or until the potential for variations in energy usage has been eliminated, whichever is sooner. Monthlv Charqes The monthly charges are as follows, and may also include charges as set forth in Schedule 55 (Power Cost Adjustment), Schedule 91 (Energy Efficiency Rider), and Schedule 95 (Adjustment for Municipal Franchise Fees). For non-metered service, the average monthly kWh of energy usage shall be estimated by the Company based on the total wattage of the Customer's lighting system and 4,059 hours of operation. Non-Metered Service (41 C) Energy Charge, per kWh 5.1670( Metered Service (41CM) Service Charge, per meter Energy Charge, per kWh $3.36 5.0536 F- \O o\oa.l - \O: r:: .!3 9^-YIc9lJz9 9&tr- Fo E^ Fvv-EZO:-H s?HFs 6 SD<(Jao IDAHO lssued per Order No. Effective - October 1, 2019 lssued by IDAHO POWER COMPANY Timothy E. Tatum, Vice President, Regulatory Affairs 1221 West ldaho Street, Boise, ldaho SERVICE OPTIONS (Continued) CERTIFICATE OF SERVICE I HEREBY CERTTFY THAT I HAVE THIS 2IST DAY OF AUGUST 2019, SERVED THE FOREGOING COMMENTS OF THE COMMISSION STAFF, IN CASE NO. IPC-E-19-17, BY MAILING A COPY THEREOF, POSTAGE PREPAID, TO THE FOLLOWING: LISA D NORDSTROM REGULATORY DOCKETS IDAHO POWER COMPANY PO BOX 70 BOrSE ID 83707-0070 E-mail : lnordstrom@idahopower.com dockets@idahopower. com TIM TATUM CONNIE ASCHENBRENNER IDAHO POWER COMPANY PO BOX 70 BOISE ID 83707-0070 E-mail: ttatum@idahopower.com caschenbrenner@ idahopower. com -b 4hr5{t SECRETARY CERTIFICATE OF SERVICE