20081119Comments.pdf

KRISTINE A. SASSER
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
BARNO. 6618
RECEIVED
200e NOV 19 AM 9: 12
IDAHO PUBUa_,¡ . ,
UTiLITIES COMMISt;i(i~Q
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 APPLICATION
OF ROCKY MOUNTAIN POWER FOR
AUTHORITY TO REVISE ITS EXISTING
RULE 12 LINE EXTENSION TARIFF.
)
) CASE NO. PAC-E-08-6
)
) COMMENTS OF THE
) COMMISSION STAFF
)
)
COMES NOW the Staff of the Idaho Public Utilties Commission, by and through its
Attorney of record, Kristine A. Sasser, Deputy Attorney General, and in response to the Notice of
Application and Notice of Modified Procedure issued in Order No. 30660 on October 23,2008 in
Case No. PAC-E-08-6, submits the following comments.
BACKGROUND
On October 10, 2008, PacifiCorp dba Rocky Mountain Power filed an Application with the
Commission seeking authority to revise its Rule 12 Line Extension taiff. More specifically, the
Company requests changes to tariff Sheet Nos. 12R.2, 12RA, 12R.5, 12R.6, 12R.7, 12R.8, 12R.12,
and 12R.13.
The Company asserts that several of its proposed changes are housekeeping measures and
meant to provide clarification of the existing language. More substantive changes are being
STAFF COMMENTS 1 NOVEMBER 19,2008
proposed for tariff Sheet Nos. 12R.4 through 12R.8. Each of these proposed changes is discussed
in detail in Staffs analysis.
STAFF ANALYSIS
Staff reviewed the proposed changes to Rocky Mountain Power's Rule 12 Line Extension
Regulation. The proposed changes in Sheet Nos. 12R.2, 12R.12 and 12R.13 are straightforward.
The changes are not substantive and will add clarity to the existing tarff. Staff believes these
changes make the taiff rules easier to understand.
The proposed changes in Sheet Nos. 12R.4, 12R.5, 12R.6, 12R.7 and 12R.8 do not appear
to be housekeeping measures, but Staff believes they are reasonable. In Sheet Nos. 12R.4 and
12R.5, the Company proposed changes to the refund methodology for residential customers. The
existing refud process requires the first additional customer connecting to the line extension to
refud 80% of the initial customer's advance. The next three additional customers wil pay 60%,
40% and 20% of the prior customer's advance with each refud going to the previous customer.
The Company noted that there are circumstances where the existing methodology creates a barrer
to the first additional customer who may be unwillng to pay 80% of the initial customer's
advance. Instead, the customer may opt to wait for the five-year refund period to expire before
connecting to the line extension, thereby avoiding any reimbursement. A customer complaint was
fied with the Commission as recently as July 8, 2008 by a customer who felt that an 80% refud
was too much. The proposed change to the refud methodology requires that the first four
additional customers pay 20% each to the initial customer. Staff supports this proposed change.
In Sheet No. 12R.6, the Company changed the heading for Sections 3(a) and 3(b) to clearly
define whether a service is high voltage or primary and secondary voltage, respectively. The
proposed language clearly defines what is included in the allowance for this tye of line extension.
The Company asserts, and Staff confirmed, that the requirement for the "Contract Minimum
Biling" is the existing practice for all customers with demands of greater than 1,000 k W. Staff
agrees with the proposed change.
In Sheet No. 12R.7, the Company added a paragraph requiring the applicant to extend the
line extension to the edge of their property. The Company noted that this is their curent
engineering practice. Staff believes that the proposed change benefits the customers because it
wil avoid disruptions to service if the Company needs to work on an additional service for a new
STAFF COMMENTS 2 NOVEMBER 19, 2008
customer. Staff believes that this method saves labor and time. Therefore, Staff supports this
proposed change.
In Sheet No. 12R.8, the Company proposed language that gives an option to a developer to
waive refuds ofless than 20%. Because there is a limit of four refuds during a five-year refud
period, this proposed change would allow the developer to reject a smaller refund in order to
preserve the opportunity for refunds that may be greater. Staff believes that the additional
language gives flexibilty to the developer and is beneficial to the customer.
RECOMMENDATIONS
Staff believes that the proposed changes to Rocky Mountain Power's Rule 12 Line
Extension Regulations are reasonable. Staff recommends that the Commission approve all of
Rocky Mountain Power's proposed changes to its Rule 12 Line Extensions Regulations.
Respectfully submitted this iq'! day of November 2008.
1J~ fl. £WV~.Kr stine A. Sasser
Deputy Attorney General
Technical Staff: TJ. Golo
Dave Schunke
i:umisc:comments/pace08.6kstjgdes.doc
STAFF COMMENTS 3 NOVEMBER 19,2008
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 19th DAY OF NOVEMBER 2008,
SERVED THE FOREGOING COMMENTS OF THE COMMISSION STAFF, IN CASE
NO. PAC-E-08-6, BY MAILING A COPY THEREOF, POSTAGE PREPAID, TO THE
FOLLOWING:
TED WESTON
ROCKY MOUNTAIN POWER
201 S MAIN ST STE 2300
SALT LAKE CITY UT 84111
E-MAIL: ted.westoncmpacificorp.com
DATA REQUEST RESPONSE CENTER
PACIFICORP
825 NE MULTNOMAH STE 2000
PORTLAND OR 97232
E-MAIL: datarequestcmpacificorp.com
SECRETARY
2D.~
CERTIFICATE OF SERVICE