20190710Decision Memo.pdf

DECISION MEMORANDUM
TO:COMMISSIONER KJELLANDER
COMMISSIONEN, RAPER
COMMISSIONER ANDERSON
COMMISSION SECRETARY
LEGAL
WORKING FILE
FROM: BENTLEY ERD1VURM
DATE:JULY 8' 2019 I Pc- F= - tc1' ??-
IDAHO POWER TARIFF ADVICE NO. 19.07;
MODIFICATIONS TO SCHEDULE 45 - STANDBY SERVICE
RE:
BACKGROUND
On June l4,z0lg,ldaho Power Company filed Tariff Advice No. 19-07 with the
Commission to modiff Schedule 45 - Standby Service, with a proposed effective date of
July 15,2019. Standby Service is currently available to customers with on-site generation taking
service at primary or transmission level voltages under Schedule 9 - Large General Service and
Schedule l9 - Large Power Service. Idaho Power now proposes to make Standby Service
available to Schedule 9 customers taking service at secondary level voltages.
STAFF ANALYSIS
Staffreviewed Idaho Power's methodology for determining the proposed Standby
Service rates, verified supporting workpapers provided by the Company, and believes that the
proposed modifications to Schedule 45 are consistent with other Standby Services offered. To
determine Standby Service rates for secondary Schedule 9 customers, Idaho Power applied the
samE methodology used to calculate rates for Schedule l9 customers in the Company's last
general rate case (IPC-E-l l -08) and for the primary and transmission Schedule 9 customers
when Schedule 45 eligibility was expanded through Tariff Advice No. l6-06 filed November l,
2016. Idaho Power made an adjustment to include the Langley Gulch power plant in base rates
by applying the 7 .05Yo rate increase (as approved in Case No. IPC-E- 12-14, with rates effective
DECISION MEMORANDUM JULY 8,20I9
July l, 2012) to the cost of service study and conesponding unit costs. The adjustment for
Langley Gulch was also performed for TariffAdvice No. 1606. Staffconfirmed that the
proposed Standby Service rates for secondary Schedule 9 sustomers are based on the most recent
cost-of-service study, as adjusted for Langley Gulch.
Staffagrees with ldaho Power's use of adjusted billing units in the Standby Service rate
calculation. This adjustment is necessary because some demand-related costs are in the first tier
of the Schedule 9 energy rate, Staffa$ees with the Company's claim that the billing
determinate adjustment is necessary to prevent the understatement of the Standby Service rates.
Additional Input
On July 3,2019, Ben Ono representing the Idaho Conservation League emailed Staff
expressing their concern that this TariffAdvice needs additionat process. He is also concerned
that it overlaps IPC-E-I8-15, IPC-E-I9-15 and possibly IPC-E- l8-16.
STAFF RECOMMENDATION
Staffreviewed the modifications to Schedule 45 * Standby Service and as slated above
believes it is consistent with Standby Servicc cunently offercd. Staff is not opposed to
additional process for TariffAdvice No. 19-07, and proposes it be treated as an Application, with
the proposed effective date suspended to allow the case to be processed by rnodified procedure
with a 2l-day comment period and a 7-day reply comment period.
COMMISSION DECISION
Does the Commission wish to treat Tariff Advicc No. l9-07 as an Application, with the
proposed cffective date suspended to allow for the case to be processed by modified procedure
with a 2l-day comment period and a 7-day reply comment period?
Bentley Erdururm
Udmcmoc'lPC Advicc l9{7 - Schcdulc 45 Sturdby
DECTSION MEMORANDUM JULY 8,20192