20090415Comments.pdf

KRSTINE A. SASSER
DEPUTY ATTORNY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
POBOX 83720
BOISE, IDAHO 83720-0074
(208) 334-,0357
BARNO. 6618
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2009 APR 15 AM II: 14
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 )
PACIFICORP DBA ROCKY MOUNTAIN )
POWER FOR AUTHORITY TO REVISE ITS )
EXISTING SCHEDULE NO. 72A IRRGATION )
LOAD CONTROL CREDIT RIDER DISPATCH )PROGRAM. )
CASE NO. PAC-E-09-1
COMMENTS OF THE
COMMISSION STAFF
COMES NOW the Staff of the Idaho Public Utilities Commission, by and through its
Attorney of record, Krstine A. Sasser, Deputy Attorney General, submits the following
comments in response to the Notice of Modified Procedure issued on March 16,2009. Order No.
30747.
BACKGROUND
On February 11, 2009, PacifiCorp dba Rocky Mountain Power ("Company") fied an
Application with the Commission seeking authority to revise its Schedule 72A Irgation Load
Control Credit Rider Dispatch Program ("Program"). More specifically, the Company requested
changes to tariff Sheet Nos. 72A.1, 72A.2, 72A.3 and 72A.4. The Company filed the Application
as a Tarff Advice with a proposed effective date of March 13,2009. The proposed modifications
included:
STAFF COMMENTS 1 APRIL 15, 2009
1. Tarff Sheet No. 72A.1 addresses the purose of Schedule 72A. The proposed
change provides the Company's rationale for preseason Internet access.
2. Tarff Sheet No. 72A.2 addresses load control service credit.
a. The Company's proposed modifications would allow the Company to
issue a credit in lieu of a check for the Load Control Service Credit
("LCSC"), at its discretion, at the end of the season.
b. Additional language was added to clarify how average demand is
calculated when two years of usage history is unavailable.
c. Language was also added to indicate that the tiered credit was designed
to promote program participation.
d. A revision was included to correct the notification date for paricipation
from February 15 to pri115.
3. The proposed changes to tar fSheet Nos. 72A.3 and 72A.4 add language to
clarify the Company's notific tion procedures for a dispatch event and revise
language to the liquidated da ages section from actual prices paid by the
Company for replacement po er to the day ahead on-peak price at Four
Corners as quoted at the Inter ontinental Exchange (ICE).
Staff reviewed the tariff advice fiing an found that the majority of the modifications
were minor and provided additional clarty to th rate schedule. The one exception was Sheet
72A.2. In a Decision Memo dated March 6, 20 9, Staff recommended suspension of the effective
date and, further, that the case be processed by odified Procedure. Staff reasoned that the 72A.2
modifications marked a significant deparure fro current Company practices and lacked any
guidelines as to when the Company would issue a credit to a program paricipant's account in lieu
of a check. The Commission granted Staffs re uest.
STAFF ANALYSIS
Staff has worked with the Company and he Idaho Irrgation Pumpers Association
("LIP A") to come up with a viable solution to th modification in payment of the LCSC.
Specifically, the parties discussed if there was appropriate level of arrearage that would
warant an account credit over a check. A conti rence call was held on Apri13, 2009 to determine
whether the paries could reach agreement. The Company contends that it had internal conflict
STAFF COMMENTS 2 APRIL 15,2009
between its collections and DSM deparments as to whether crafting more definitive language was
appropriate. From the Collections standpoint, at the end ofthe 2008 Program season the
Company paid nearly $5.9 million in LCSC while having nearly $3.3 milion in past due accounts
for the irrgation class. The main concern of the DSM staff was negative customer perception that
might impact paricipation in the Program. The originally proposed language allowed the
Company to address the issuance of the LCSC on a case by case basis.
Staff believes the Company underestimates the value placed on the certainty of its
practices. Staff is concerned that the Company's proposal could lead to discordant application of
the LCSC payment, thus aggravating participants more so than if an explicit standard were
included in the tarff. During the April 4 conference call, LIP A stated that the organization is
generally supportive of the modification in payment protocol if guidelines are provided in the
tariff. lIP A assured the Company that the matter had been discussed in a recent board meeting,
and the board did not believe Program participation would be affected should a reasonable
time frame be adopted. IIPA also recognzed that reducing uncollectables and delinquent accounts
have benefits to the class as a whole.
Staff suggested that a proper limit for arrearage, and thus credit issuance, be between 30
and 60 days from the end of the Program season. Following the conference call and input by both
Staff and LIP A, the Company submitted revised language to address the concerns in Sheet 72A.2.
The Company now recommends that accounts more than 30 days past due, two weeks prior to
LCSC issuance, receive a credit toward the past due amount. The newly proposed language is as
follows:
The LCSC for a participating site shall be calculated and issued to the paricipating
customer in the form of a check, or as a credit against the participating site account if an
outstanding account balance exists that is 30 days or more past due two weeks before the
credit issuance. The LCSC wil be issued no later than October 31 following each
irrgation season.
STAFF RECOMMENDATION
Staff finds the Company's newly submitted language to be a reasonable accommodation
in terms of the LCSC and account arrearage, and recommends the Commission adopt this revised
proposal for Sheet 72A.2. Should the LCSC exceed the account balance, the Company would
issue a check to the participant for the difference. Further, Staff recommends that the additional
revisions as submitted in PacifiCorp Tarff Advice 09-01, which are not in dispute, be adopted.
STAFF COMMENTS 3 APRIL 15,2009
~I-
Respectfully submitted this i r:~ day of April 2009.
~)a.~
Kr me A. Sasser
Deputy Attorney General
Technical Staff: Bryan Lanspery
i:umisc:comments/pace09.lksbl comments
STAFF COMMENTS 4 APRIL 15,2009
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 15TH DAY OF APRIL 2009,
SERVED THE FOREGOING COMMENTS OF THE COMMISSION STAFF, IN
CASE NO. PAC-E-09-01, BY MAILING A COpy THEREOF, POSTAGE PREPAID,
TO THE FOLLOWING:
JEFFREY K LARSEN
VP REGULATION
ROCKY MOUNTAIN POWER
201 S MAIN ST STE 2300
SALT LAKE CITY UT 84111
DATA REQUEST RESPONSE CENTER
PACIFICORP
825 NE MUL TNOMAH STE 2000
PORTLAND OR 97232
E-MAIL: datarequest(fpacificorp.com
~SECRETARY
CERTIFICATE OF SERVICE