20120511Amended Application.pdf

ROCKY MOUNTAIN
( POWER
A DIVISION OF PACIACOAP
May 11, 2012
VIA OVERNIGHTDELIVERY
201 South Main, Suite 2300
Salt Lake City, Utah 84111
RE CE 1, V ED
2912 MAY It AM 10: 14
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U i ItJ C 1 .SIOi
Jean D. Jewell
Commission Secretary
Idaho Public Utilities Commission
472 W. Washington
Boise, ID 83702
Re: Case No. PAC-E-12-02
IN THE MATTER OF THE APPLICATION OF ROCKY MOUNTAIN
POWER FOR MODIFICATIONS TO THE SERVICE AND
PERFORMANCE QUALITY REPORTING
Dear Ms. Jewell:
Please find enclosed for filing an original and seven copies of Rocky Mountain Power's
amended Application in the above-referenced matter.
All formal correspondence and regarding this Application should be addressed to:
Ted Weston Daniel E. Solander
Rocky Mountain Power Rocky Mountain Power
201 South Main, Suite 2300 201 South Main Street, Suite 2300
Salt Lake City, Utah 84111 Salt Lake City, Utah 84111
Telephone: [phone] Telephone: [phone]
Fax: [phone] Fax: [phone]
Email: [e-mail] Email: [e-mail]
Communications regarding discovery matters, including data requests issued to Rocky
Mountain Power, should be addressed to the following:
By E-mail (preferred): datarequestpacificorp.com
By regular mail: Data Request Response Center
PacifiCorp
825 NE Multnomah St., Suite 2000
Portland, OR 97232
Idaho Public Utilities Commission
May 11, 2012
Page 2
Informal inquiries may be directed to Ted Weston, Idaho Regulatory Manager at (801) 220-
2963.
Very truly yours,
Jeffrey K. Larsen
Vice President, Regulation & Government Affairs
Enclosures
Mark C Moench
Sr. VP and General Counsel
201 South Main, Suite 2400
Salt Lake City UT 84111
Telephone: [phone]
FAX: [phone]
Email mark moench)pacificorp corn
Daniel E. Solander
Senior Counsel
201 South Main, Suite 2300
Salt Lake City UT 84111
Telephone: [phone]
FAX: [phone]
Email: [e-mail]
Attorneys for Rocky Mountain Power
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION ) CASE NO PAC-E-12-02
OF ROCKY MOUNTAIN POWER FOR )
MODIFICATIONS TO THE SERVICE AND ) AMENDED
PERFORMANCE QUALITY REPORTING ) APPLICATION
Comes now, PacifiCorp, d/b/a Rocky Mountain Power and hereby applies to the Idaho
Public Utilities Commission requesting authorization to modify the Company's existing
Performance Standards program In support of this Application, Rocky Mountain Power
represents as follows
I. Background
As part of Order No. 28213 approving the ScottishPower / PacifiCorp merger the
Company agreed to implement Network Performance Standards, Service Performance Standards
and Customer Guarantees The Company committed to a five-year term for the program and
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began offering the Customer Guarantees on February 29, 2000. Improvements to Network and
Service performance standards were initiated at approximately the same time. This program
expired on March 31, 2005, but was extended voluntarily and later affirmed and further extended
through December 31, 2011 in Order No. 29998 as part of the merger commitments of
MidAmerican Energy Holding Company when acquiring PacifiCorp.
The purpose behind the Service Performance Standards is to improve customer service
while emphasizing to employees that customer service and system reliability are a top priority.
This focus on reliability and individual transactions with customers has improved the Company's
operations and been effective in setting priorities for employees as they conduct their daily work.
These programs have been very effective and the Company has successfully implemented them
as demonstrated by its semi-annual Service Standard Program reports.
On June 4, 2008, PacifiCorp filed an application requesting authorization to modify the
Network Performance Standards. The application proposed that the basis for developing targets
be modified in order to continue cost-effective improvements in system wide reliability and to
maintain responsiveness in the event of outages. The Company proposed that improvement
targets should be developed around outage events that are of a controllable nature on the
distribution system, and therefore developed the category of "Controllable Distribution" outages.
Controllable outage events are attributed to causes against which the Company is able to
implement system improvements that have a high probability of avoiding future recurrence at a
local level. For example, outages that are related to equipment failure or animal interference are
controllable distribution outages since the Company can take measures to avoid them in the
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future and have some fairly high certainty these events will not recur. On the other hand,
transmission outage events and car-hit-pole interference outage events do not conform to the
definition of controllable distribution, and while important to avoid, are generally not avoidable
via engineered programs.
In Order No. 32432, the Final Order from the 2011 general rate case, PAC-E-11-12, the
Commission ordered the Company to continue its service performance and quality reporting
requirements including those associated with momentary and longer-term service interruptions
occurring in the Idaho service territory.
II. PROPOSED MODIFICATIONS
MEHC merger Commitment 45 states: "MEHC and PacifiCorp commit to continue
customer service guarantees and performance standards as established in each jurisdiction,
provided that MEHC and PacifiCorp reserve the right to request modifications of the guarantees
and standards after March 31, 2008, and the right to request termination (as well as modification)
of one or more guarantees or standards after 2011. The guarantees and standards will not be
eliminated or modified without Commission approval."
Recognizing the value of the Customer Guarantee and Performance Standards programs
and that the merger commitments would be completed by December 31, 2011, the Company
initiated meetings on July 13 and December 14, 2011, with Commission staff to discuss the
continuation of these two programs.
The Company recommended that the programs continue as part of its regular business
with no changes to the Customer Guarantees and Customer Service Performance standards. The
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Company is requesting Commission approval of the proposed modifications to Network
Performance Standards one, two, and three.
Network Performance Standards 1, System Average Interruption Duration Index
("SAID!") and 2, System Average Interruption Frequency Index ("SAIFI") performance targets
are currently based on improving controllable distribution outage events The modifications the
Company proposes for Standards 1 and 2 are:
(1)Re-establish baseline performance targets from the current controllable
distribution outage events to reporting reliability performance based on underlying
distribution events. . Underlying distribution events include all outages excluding major
events and prearranged (customer notice given and customer requested) outages. These
events better represent the overall outages customers experience, moderately align to the
normal day to day reliability performance of the distribution system, and provides a
consistent view of the performance of the system to evaluate trends.
(2)The Company will also report total and controllable distribution reliability
performance for the reporting period.
(3)Provide a rolling twelve-month performance for Controllable, Non-
Controllable, and Underlying distribution events.
(4)For actual performance variations from underlying baseline performance,
explanations of performance will be provided and the Company will determine the
appropriate course of action for improvement, as necessary, as part of normal business
operations to maintain reliability performance.
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Network Performance Standard 3 currently provides that the Company will select a
maximum of two underperforming circuits in Idaho on an annual basis and undertake corrective
measures to reduce the average circuit performance indicator (CPI) by twenty percent within five
years after selection The Company requests authority to modify Network Performance Standard
3 to allow the Company to identify at least one underperforming area of concern, rather than
circuits, in Idaho on an annual basis and undertake corrective measures to reduce the reliability
performance indicator' ("RPI") by ten percent within five years after identification A target
area can be a circuit section, a circuit or a subset of multiple circuits or sections. Shifting the
focus of the standard to underperforming areas will allow the Company to be more effective
when creating improvement plans
The RPI metric (and the improvement target) for this standard is measured based on
controllable distribution outages As identified previously, it is reasonable to measure
performance for engineering programs using controllable distribution outages The Company
will identify the criteria used for determining the under-performing areas and the plans to address
them The Company will also work with Commission Staff to develop methods to report the
target area performance and cost-benefit results
An attachment to this Application contains the Customer Guarantees, Customer
Performance Standards and Network Performance Standards updated with the proposed revisions
to Network Performance Standards 1, 2, and 3
III MODIFIED PROCEDURE
1 Reliability performance indicator (RPI) will be calculated using controllable interruptions for SALDI, SAIFI, and
MAIFI, and are exclusive of major events as calculated by IEEE 1366-2012; this is a modification to the Company's
historic CPI. RPI excludes breaker lockout events.
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Rocky Mountain Power believes that a hearing is not necessary to consider the issues
presented herein and, therefore, respectfully requests that this Amended Application be
processed under Modified Procedure, i.e., by written submissions rather than by hearing. RP 201
et seq. If, however, the Commission determines that a technical hearing is required, the Company
stands ready to present its testimony and support the Application in such hearing
IV REQUEST FOR RELIEF
Rocky Mountain Power respectfully requests that the Commission issue an Order
(1) authorizing that this matter may be processed by Modified Procedure, (2) acknowledging that
MEHC met its merger commitment by successfully delivering the Customer Guarantees,
Network Performance Standards, and Customer Performance Standards programs through
December 31, 2011; (3) eliminating the requirement to include these items in the annual merger
commitment report and, (4) approving the proposed modification to Network Performance
Standards 1, 2, and 3
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DATED: May 11, 2012.
Mark C. Moench
Sr. VP and General Counsel
201 South Main, Suite 2400
Salt Lake City UT 84111
Telephone: [phone]
FAX: [phone]
Email: mark.moench(Dacificoracom
Daniel E. Solander
Senior Counsel
201 South Main, Suite 2400
Salt Lake City UT 84111
Telephone: [phone]
FAX: [phone]
Email: dathel.solander(nacificorn.com
Attorneys for Rocky Mountain Power
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ROCKY MOUNTAIN
POWER
A Of VISION OF PACIFICORP
Idaho Customer Guarantees
Customer Guarantee 1: The Company will restore supply after an
Restoring Supply After an Outage outage within 24 hours of notification with
certain exceptions as described in Rule 25.
Customer Guarantee 2: The Company will keep mutually agreed
Appointments upon appointments which will be
scheduled within a two-hour time window.
Customer Guarantee 3: The Company will switch on power within
Switching on Power 24 hours of the customer or applicant's
request, provided no construction is
required, all government inspections are
met and communicated to the Company
and required payments are made.
Disconnections for nonpayment,
subterfuge or theft/diversion of service are
excluded.
Customer Guarantee 4: The Company will provide an estimate for
Estimates For New Supply new supply to the applicant or customer
within 15 working days after the initial
meeting and all necessary information is
provided to the Company.
Customer Guarantee 5: The Company will respond to most billing
Respond To Billing Inquiries inquiries at the time of the initial contact.
For those that require further investigation,
the Company will investigate and respond
to the Customer within 10 working days.
Customer Guarantee 6: The Company will investigate and respond
Resolving Meter Problems to reported problems with a meter or
conduct a meter test and report results to
the customer within 10 working days.
Customer Guarantee 7: The Company will provide the customer
Notification of Planned Interruptions with at least two days notice prior to
turning off power for planned
I interruptions.
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'ROCKY MOUNTAIN
POWER
A 0VISI0N OF PACIRCORP
Idaho Performance Standards
Network Performance Standard 1: The Company will report Total,
Underlying, and Controllable SAIDI and Report System Average Interruption
Duration Index (SAIDI) identify annual Underlying baseline
performance targets for the reporting
period. For actual performance variations
from baseline, explanations of performance
will be provided. The Company will also
report rolling twelve month performance
for Controllable, Non-Controllable and
Underlying distribution events.
Network Performance Standard 2: The Company will report Total,
Underlying, and Controllable SAIFI and Report System Average Interruption
Frequency Index (SAIFI) identify annual Underlying baseline
performance targets for the reporting
period. For actual performance variations
from baseline, explanations of performance
will be provided. The Company will also
report rolling twelve month performance
for Controllable, Non-Controllable and
Underlying distribution events.
Network Performance Standard 3: Annually the Company will select at least
Improve' Under-Performing Areas one underperforming area based upon a
reliability performance indicator 2 (RP1).
Within five years after selection the
Company will reduce the RPI by an
average of 10% for the areas selected in a
given year. The Company will identify the
criteria used for determining these areas
and the plans to address them.
Network Performance Standard 4: The Company will restore power outages
Supply Restoration due to loss of supply or damage to the
distribution system within three hours to
80% of customers on average.
When in the future, the Company discovers that marginal improvement costs outweigh marginal
improvement benefits, the Company can propose modifications to the Performance Standards Program to
recognize that maintaining performance levels is appropriate.
2 Reliabili' performance indicators (RPI) will be calculated using controllable interruptions for SAIDI
SAM, and MAIFI, and are exclusive of major events as calculated by IEEE 1366-2012; they are a
modification to the Company's historic CPI. RPI excludes breaker lockout events.
Prospectively, the Company will worth with Commission Staff to determine methods to report the target
area performance and cost-benefit results
2
Customer Service Performance Standard The Company will answer 80% of
telephone calls within 30 seconds The Telephone Service Level
Company will monitor customer
satisfaction with the Company's Customer
Service Associates and quality of response
received by customers through the
Company's eQuality monitoring system.
Customer Service Performance Standard The Company will a) respond to at least
95% of non-disconnect Commission 6:
Commission Complaint Response / complaints within three working days and
Resolution will b) respond to at least 95% of
disconnect Commission complaints within
four working hours, and will c) resolve
95% of informal Commission complaints
within 30 days.