20190805Comments.pdf

EDWARD J. JEWELL
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 10446
IN THE MATTER OF THE APPLICATION OF
IDAHO POWER TO MODIFY SCHEDULE 45,
STANDBY SERVICE.
REC E IVED
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CASE NO. IPC-E..19-22
Street Address for Express Mail:
472W. WASHINGTON
BOISE, IDAHO 83702-5918
Attorney for the Commission Staff
BEFORE THB IDAHO PUBLIC UTILTTIES COMMISSION
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COMMENTS OF THE
COMMISSION STAF'F
The Staff of the Idaho Public Utilities Commission comments as follows on Idaho Power
Company' s Application.
BACKGROUND
On June 14,2019, the Company submitted Tariff Advice No. 19-07 requesting
modification to Schedule 45, Standby Service ("Standby Service") to expand the availability of
Standby Service to Schedule 9, Large General Service customers, who take service at the
secondary service level ("9S customers"). The Company requested an effective date of
July 15,2019.
At the July 9, 2019 Decision Meeting, Commission Staff presented a Decision
Memorandum noting that a public comment had been received requesting the Tariff Advice be
processed as an Application. Staff recommended the Commission process the Tariff Advice as
an Application through Modified Procedure.
ISTAFF COMMENTS AUGUST 5,2019
The Commission suspended the effective date and converted the Tariff Advice into an
Application to be processed by Modified Procedure with established comment and reply
comment deadlines. Order No. 34377.
The Company states it calculated the rates for Standby Service for Schedule 95
customers according to the methodology approved by the Commission for Schedule 19 P/T
(primary/transmission) customers and Schedule 9 P/T customers, with an adjustment for the
difference in rate design for Schedule 95 customers. If the Application is approved, customers
taking service under Schedule 95 would be charged as follows for Standby Service: (1) a
Standby Reservation Charge of $4.75lkW of Available Standby Capacity in the summer and
$4.32lkw of Available Standby Capacity in the non-summer; and (2) a Standby Demand Charge
of $7.20lkW of Standby Billing Demand in the summer and $5.90/kW of Standby Billing
Demand in the non-summer.
STAFF REVIEW
Staff reviewed Idaho Power's methodology for determining the proposed Standby
Service rates, studied supporting workpapers provided by the Company, and verified that the
proposed modifications to Schedule 45, including the new rates for Schedule 95, are consistent
with other Standby Services. Staff recommends the Commission approve the modifications to
Schedule 45.
To determine Standby Service rates for Schedule 95 customers, Idaho Power applied the
same methodology used to calculate Standby Service rates for Schedule 19 customers in the
Company's last general rate case (IPC-E-1 1-08) and for the Schedule 9 PIT customers when
Schedule 45 eligibility was expanded through Tariff Advice No. 16-06 filed November 1 ,2016.
Idaho Power made an adjustment to include the Langley Gulch power plant in base rates by
applying the 7.05o/o rate increase (as approved in Case No. IPC-E-12-14, with rates effective
July 1, 2012) to the cost of service study and corresponding unit costs. The adjustment for
Langley Gulch was also performed for Tariff Advice No. 16-06. Staff confirmed that the
proposed Standby Service rates for Schedule 95 customers are based on the most recent cost-of-
service study, as adjusted for Langley Gulch.
Staff agrees with Idaho 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
2STAFF COMMENTS AUGUST 5,2079
of the Schedule 9 energy rate. Staff agrees with the Company's claim that the billing
determinate adjustment is necessary to prevent the understatement of the Standby Service rates.
On July 3,2019, counsel for the Idaho Conservation League emailed Staff expressing his
client's concern that the Company's proposal overlaps with issues addressed in IPC-E-18-15,
IPC-E-19-15, and possibly IPC-E-18-16. Staff does not believe that it is appropriate to consider
Standby Service rates in IPC-E- I 8- 15 because that case applies only to residential and small
commercial customers. Although IPC-E-18-16 applies to all rate classes, it has not specifically
addressed Standby Service rates. IPC-E-I9-15, which applies to Schedule 9, is still underway.
However, expanding Standby Service to Schedule 95 customers in this case using an approach
accepted in two prior cases supports the equal treatment of similarly-situated Schedule 9
customers. Staff believes it is inappropriate to deny Standby Services to customers requesting
this service pending inclusion in or the outcome of these other cases. Any further change in rates
or rate design is appropriately determined in a future proceeding.
STAFF RECOMMENDATIONS
Staff recommends the Commission approve the modifications to Schedule 45 - Standby
Service. Approving the Company's modifications to Schedule 45 would expand the availability
of Standby Service to secondary service customers, which would provide secondary Schedule 9
customers the same opportunities to install on-site generation as similarly-situated primary and
transmission customers.
5*Respectfully submitted this day of August 2019
Edward J
Deputy General
Technical Staff: Bentley Erdwurm
i :umisc/comments/ipce I 9.22ejbe comments
aJSTAFF COMMENTS AUGUST 5,2019
a-lrArt
CBRTIFICATB OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 5th DAY OF AUGUST 2019,
SERVED THE FOREGOING COMMENTS OF THE COMMISSION STAFF,IN
CASE NO. IPC-E-19-22, BY MAILING A COPY THEREOF, POSTAGE PREPAID, TO
THE FOLLOWING:
LISA D NORDSTROM
REGULATORY DOCKETS
IDAHO POWER COMPANY
PO BOX 70
BOISE ID 83707-0070
E-mail : [e-mail]
dockets@idahopower. com
CERTIFICATE OF SERVICE