20070516Comments.pdf

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DONOV AN E. WALKER
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 5921
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Street Address for Express Mail:
472 W. WASHINGTON
BOISE, ID 83702-5983
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION OF
ROCKY MOUNTAIN POWER FOR REVISIONS)
TO STREET LIGHTING SERVICES.
CASE NO. P AC-O7-
COMMENTS OF THE
COMMISSION STAFF
The Staff of the Idaho Public Utilities Commission, by and through its Attorney of record
Donovan E. Walker, Deputy Attorney General, in response to the Notice of Application and
Notice of Modified Procedure issued in Order No. 30309 on April 25, 2007 , respectfully submits
the following comments.
THE COMPANY'S APPLICATION
On April 17, 2007, Rocky Mountain Power filed an Application for authority to revise its
Electric Service Schedule No. 11 (Company-Owned Overhead System), Schedule No. 12
(Customer-Owned System), and Electric Service Regulation No. 12 (Line Extensions), regarding
revisions to the Company s street lighting schedules.
The Company states the purpose of this Application is to revise its street lighting schedules
to clarify applicability, include expanded lighting options such as metal halide and decorative
lighting, to close non-standard lights to new service, and to add or rewrite service provisions
ST AFF COMMENTS MAY 16 2007
clarifying Company and customer obligations surrounding the installation, conversion, and
maintenance of facilities. As stated in the Application, the proposed changes are responsive to
customer inquiries regarding expanded street lighting offerings.
The Application states that the Company has shared its proposals with representatives of
multiple cities within its service territory and has worked with Commission Staff to develop this
Application. The Company has sent a letter detailing its proposal to all customers receiving
service under Schedules 11 and 12. The Company serves approximately 19 customers with 188
lights under Schedule 11 , and 51 customers totaling 3 574 lights under Schedule 12. Of the 3 574
customer-owned lights, 3 406 receive full company maintenance and another 160 receive partial
maintenance.
The specific changes to Schedule 11 include: (a) metal halide and decorative fixture
options are added; (b) non-standard light sizes are closed to new service, existing fixtures will
continue to be maintained; ( c) service to pole-mounted outlets is to be provided under a metered
general service rate; (d) contract term requirement is extended from three to five years; and (e) the
schedule name is changed to Street Lighting Service - Company-Owned System.
The specific changes to Schedule 12 include: (a) standard lights are listed in the tariff with
monthly lamp rates, a per kilowatt hour rate is available for non-listed, energy-only luminaries; (b)
monthly maintenance will no longer be offered for new consumer-owned lights; however, the
Company will continue to perform maintenance under existing service agreements; (c) installation
maintenance, transferring, or removal of lights must be performed by qualified personnel or, if
qualified personnel are not available, by the Company at the consumer s expense; (d) service to
pole-mounted outlets is to be provided under a metered general service rate; (e) references to light
sizes in the "no new service" section are removed where there are no longer any active
agreements; (f) references to low pressure sodium vapor 8 000, 13 500, and 22 500 lumens are
removed from energy only; and (g) traffic and other signal system service is removed and is
instead referenced to metered general service, the title of Schedule 12 is changed to Street
Lighting Service - Consumer-Owned System.
The Company also proposes to add language to the existing Rule 12 for line extensions
specifying a street lighting line extension allowance equal to five years of revenue, based on the
applicable rates for the lights to be added under Company-owned street lighting service. The
STAFF COMMENTS MAY 16 2007
allowance will be applied toward the cost of installing the required facilities and connecting to the
Company s system. The consumer must advance any costs exceeding this allowance.
STAFF ANALYSIS
Staff worked with the Company in the development of this proposal and believes it
represents a reasonable response to changing market conditions, and is structured in a manner that
will protect existing customers. The new products were proposed by the Company in response
requests from customers. The Company provided an analysis that indicated the prices for the new
products were established using the same general procedures as those for the existing products
and should provide the Company a comparable return.
The products being closed to new service are more expensive to buy and operate than other
sizes, and therefore are facing a declining market share. The Company claimed it could no longer
justify maintaining an inventory of these products, based upon market conditions. The Company
initial concept was to completely eliminate these products from the lighting options for which the
Company provides lease and/or maintenance services. This would have forced existing customers
to take over maintenance of their existing fixtures. After discussions with Staff, the proposal was
modified to limit service to existing customers. This provided the Company with most of the
reduction in inventory requirements they desired, and protected existing customers by providing a
gradual and manageable transition to the more efficient fixtures.
Although relatively limited, there are circumstances where the eliminated products are the
most appropriate fixture for the application. Staff finds that retaining these fixtures in the products
for which the Company provides energy, but not maintenance, is sufficient to meet these
applications.
The line extension provisions provide clarity and consistency in how the Company
addresses the costs of line extensions required for street lighting purposes. It is consistent with the
Company s general line extension policies, but tailored specifically to street lighting applications.
Staff believes this will reduce customer confusion over when charges will be imposed and result in
more consistency in the application of line extension charges to street lighting customers.
STAFF COMMENTS MAY 16 2007
STAFF RECOMMENDATION
Staff recommends approval of Rocky Mountain Power s Application to revise its street
lighting schedules, Schedule 11 and Schedule 12.
Respectfully submitted this day of May 2007.
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Donovan E. Walker
Deputy Attorney General
Technical Staff: Wayne Hart
i :umisc:comments/paceO7 ,6dwwh
STAFF COMMENTS MAY 16 2007
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 16TH DAY OF MAY 2007
SERVED THE FOREGOING COMMENTS OF THE COMMISSION STAFF, IN CASE
NO. PAC-07-, BY MAILING A COpy THEREOF, POSTAGE PREPAID, TO THE
FOLLOWING:
DEAN BROCKBANK ESQ
ACIFICORP
DBA ROCKY MOUNTAIN POWER
201 S MAIN ST STE 2300
SALT LAKE CITY UT 84111
MAIL: dean.brockbank~pacificorp.com
BRIAN DICKMAN
P ACIFICORP
DBA ROCKY MOUNTAIN POWER
201 S MAIN ST STE 2300
SALT LAKE CITY UT 84111
MAIL: brian.dickman~pacificorp.com
DATA REQUEST RESPONSE CENTER
P ACIFICORP
825 NE MULTNOMAH STE 2000
PORTLAND OR 97232
MAIL: datarequest~pacificorp.com
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'K~SE TARY
CERTIFICATE OF SERVICE