20021121Comments.doc

LISA NORDSTROM
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
BAR NO. 5733

Street Address for Express Mail:
472 W. WASHINGTON
BOISE, IDAHO 83702-5983

Attorney for the Commission Staff

BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION

IN THE MATTER OF THE PACIFICORP APPLICATION FOR APPROVAL OF CHANGES TO THE RULES AND CHARGES FOR TEMPORARY SERVICE CONNECTION FACILITIES.
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CASE NO. PAC-E-02-6

COMMENTS OF THE
COMMISSION STAFF

COMES NOW the Staff of the Idaho Public Utilities Commission, by and through its attorney of record, Lisa Nordstrom, Deputy Attorney General, and submits the following comments in response to the Notice of Application, Notice of Modified Procedure, Notice of Comment/Protest Deadline and Order No. 29138 issued on October 29, 2002.

Background
On October 3, 2002, PacifiCorp (Company) filed an Application seeking approval of certain changes to its Electric Service Schedule Nos. 14 and 300 and Electric Service Regulation No. 12 concerning temporary service connection facilities. The Company requested that these proposed revisions become effective December 4, 2002.
PacifiCorp’s Application proposes that it no longer serve as the supplier of temporary service connection facilities in its Idaho service territory. This would close Schedule No. 14 to new service. The Company received 334 requests for temporary power installations in 2001 and 298 temporary power installations are currently in service.
The Company bases its proposal on the fact that temporary service connection facilities are readily available at home improvement stores and can be obtained easily by customers or contractors as needed. Purchasing and warehousing temporary service facilities in order to have a supply available for lease creates unnecessary costs and an administrative burden for the Company. Moreover, the Company does not provide temporary service connection facilities in any other state in its service territory. Utah and Wyoming eliminated the requirement to provide temporary service facilities in the late 1990s. PacifiCorp indicated that neither Avista Utilities nor Idaho Power offer this service in the state of Idaho. The Company also noted that the State of Idaho Division of Building Safety imposed new requirements for suppliers of temporary service connection facilities on June 26, 2002, that will create additional costs for the Company.
The majority of the Company’s customers who request temporary service facilities are contractors. PacifiCorp’s Application stated that the Company was communicating with Idaho contractors it has worked with in the past to inform them of this Application. In some areas, local contractors are already supplying their own temporary services, as PacifiCorp’s does not meet their needs.
The Company also proposed to increase the $45 charge for connection and disconnection of temporary service facilities to $85 for single-phase and $115 for three-phase service. The Company estimated that the cost of connecting and disconnecting service ranges from $81 to $233, as the necessary labor involved ranges from one to three hours. The Company argued that the existing charge for this service is considerably less than the cost of providing this service. PacifiCorp further asserted that this proposed charge is consistent with what the Company charges for this service in other jurisdictions.

Analysis
The Commission’s Notice of the Application was sent to those individuals most likely to be affected by PacifiCorp’s proposed changes. Notice was specifically sent to 54 building contractors identified by PacifiCorp with whom the Company most often does business. A letter describing the proposed changes was also sent by the Company to over 150 electrical contractors who do business in PacifiCorp’s Idaho service territory. A copy of the Commission’s Notice was sent to these electrical contractors as well.
Staff’s investigation confirmed that temporary service connection facilities are readily available at home improvement stores and can be obtained easily by customers or contractors as needed. Staff also confirmed that the Company does not provide temporary service connection facilities in any other state in its service territory.
In addition, Staff reviewed the policies of both Idaho Power and Avista regarding temporary service connection facilities. Neither Idaho Power nor Avista has provided temporary service connection facilities to contractors or customers for many years. The fact that neither of these utilities has provided these facilities for many years substantiates the argument that the equipment is, in fact, readily available. Staff does not believe that there is any compelling reason for PacifiCorp to continue to be required to provide these readily available facilities.
Because PacifiCorp has provided temporary service connection facilities in the past, some of these facilities remain installed at construction sites. Staff proposes that PacifiCorp be required to allow customers and contractors who are currently using temporary facilities to continue doing so until construction of their projects is complete. Once the projects are complete, the facilities would be returned to the Company and retired. Staff concurs with PacifiCorp’s proposal that it not be required to provide facilities in response to any new requests.
Staff does not oppose the Company’s proposal to increase the $45 charge for connection and disconnection of temporary service facilities to $85 for single-phase and $115 for three-phase service. Idaho Power and Avista both charge fees for the same service that are higher than PacifiCorp’s current fee. Idaho Power charges a temporary service connection fee of $120 for overhead service and $140 for underground service. Avista charges a temporary service connection fee for residential customers of $60 plus the cost of any additional required labor or materials that will not be used in the permanent service.
Staff believes that the estimated range of actual costs for connecting and disconnecting service cited by PacifiCorp is accurate. Furthermore, Staff believes that an increase in the temporary service connection fee is warranted.

Recommendations
Staff recommends that the Commission approve PacifiCorp’s request to close Schedule No. 14 to new service. Staff also recommends the Commission approve the Company’s request to increase the charge for connection and disconnection of temporary service to $85 for single-phase and $115 for three-phase service.

Respectfully submitted this day of November 2002.

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Lisa Nordstrom
Deputy Attorney General

Technical Staff: Rick Sterling

i:umisc/comments/pace02.6Lnrps
Temporary service connection facilities normally include a temporary power pole, a meter base, a main switch and breaker panel and a limited number of electrical outlets. Temporary service connection facilities are typically installed to provide electrical service at construction sites.

STAFF COMMENTS 1 NOVEMBER 21, 2002