20120327Comments.pdf

KRISTINE A. SASSER
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
P0 BOX 83720
BOISE, IDAHO 83720-0074
[phone]
BAR NO. 6618
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UTLITtES COWMSStO
Street Address for Express Mail:
472 W. WASHINGTON
BOISE, IDAHO 83702-5918
Attorneys for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION
OF PACIFICORP DBA ROCKY MOUNTAIN ) CASE NO. PAC-E-124
POWER FOR AUTHORITY TO MODIFY )
ITS SCHEDULE NOS. 7, 7A, AND 11 AND )
ELECTRIC SERVICE REGULATION ) COMMENTS OF THE
NO. 12. ) COMMISSION STAFF
COMES NOW the Staff of the Idaho Public Utilities Commission, by and through its
Attorney of record, Kristine A. Sasser, Deputy Attorney General, submits the following
comments in response to the Notice of Application and Notice of Modified Procedure issued on
March 6, 2012, Order No. 32474.
BACKGROUND
On January 18, 2012, PacifiCorp dba Rocky Mountain Power (Company) filed Tariff
Advice No. 12-01 proposing revisions to its Security Area Lighting (Schedule Nos. 7 and 7A) and
Street Lighting (Schedule No. 11) tariffs and Line Extension Regulation (Regulation No. 12).
Rocky Mountain Power requested that its proposed changes take effect on February 17, 2012.'
'On February 16, 2012, Rocky Mountain Power notified the Commission by e-mail that it agreed to suspension of its
proposed effective date.
STAFF COMMENTS 1 MARCH 27, 2012
After reviewing the filing, Staff recommended that the Commission suspend Rocky
Mountain Power's proposed February 17 effective date and process the tariff advice through the use
of Modified Procedure because of the numerous revisions across several rate schedules, including a
proposed change to a regulation.
The Company proposes to remove low-pressure sodium vapor lamps from Schedule No. 7
and 7A.
The Company proposes to specify no new service for customer-owned/customer-maintained
energy only service for Schedule No. 7.
The Company wishes to clarify obligations to repair inoperable lights and cost responsibility
for premature replacement of operable lights for Schedule Nos. 7, 7A and 11.
The Company proposes to add language regarding temporary disconnect cost obligations,
pole painting and light shielding for Schedule Nos. 7, 7A and 11.
The Company proposes to remove metal halide lamps from Schedule No. 11.
The Company wishes to clarify its extension allowance in Electric Service Regulation
No. 12, which affects customers taking service under Schedule Nos. 11 and 12.
Rocky Mountain Power also proposes several general "housekeeping" type changes.
STAFF ANALYSIS
The Company seeks to discontinue offering service for low pressure sodium vapor (LPSV)
lamps under Schedule Nos. 7 and 7A. LPSV lamps are used for security lighting, as are mercury
vapor lamps and high pressure sodium vapor lamps. While generally considered quite efficient,
LPSV lamps are not utilized as much as the other options, presumably due to poor color retention
and a monochromatic orange-yellow light output.2 Rocky Mountain Power has had no LPSV lamp
customers in the past five years; therefore, Staff does not believe the Company's request would
have a revenue shifting impact to other Schedule 7 customers.
Similarly, the Company has had no Schedule 11 customers with metal halide Street lighting
within the past five years. Rocky Mountain Power notes that federal legislation has made
maintaining metal halide lamps more expensive and difficult. The 2007 Energy Independence and
Security Act established higher efficiency standards for metal halide lamps, effectively preventing
the sale of probe-start fixtures. High pressure sodium vapor lamps are the more common street
2 LPSV lamps tend to wash out color, causing objects to appear as a yellowish black-and-white version of itself.
STAFF COMMENTS 2 MARCH 27, 2012
lighting option due to greater efficiency and longer fixture life. A comparison of lighting options
for Schedule Nos. 7, 7A, and 11 are included as Attachment A. Given the lack of customer
acceptance of LPSV lamps and metal halide street lights, Staff does not believe current or future
customers are unduly harmed by not having these options available.
The Company also proposes to add provisions clarifying its obligations for repair,
maintenance, pole repainting, and glare or vandalism shielding for Schedules 7, 7A, and 11. Most
of the tariff language additions comport to the Company's current practices, with one exception.
Rocky Mountain Power proposes that Schedule 11 customers who request removal of lights be
responsible for any associated costs. Staff believes this is a reasonable modification, and is similar
to the practices of Idaho Power and Avista Utilities. The Company has indicated to Staff that the
requested revisions have been incorporated in corresponding rate schedules in Wyoming, and plans
a similar filing in Utah.
Finally, Rocky Mountain Power proposes making customer advances toward non-residential
street lighting extensions non-refundable (found in Electric Service Regulation No. 12 and
applicable to Schedule Nos. 11 and 12). The Company calculates an extension allowance as five
times the annual revenue from the lights to be added, and the customer advance would be applied
toward costs that exceed this amount. Given the methodology used to calculate the allowance, Staff
believes customer contributions would be minimal, if necessary at all. Staff also considers this an
equitable alternative to having these costs recovered from other street lighting customers through
base rates.
Staff considers the Company's proposed revisions reasonable and unlikely to materially
affect current or future customers. There have been no public comments filed in opposition in this
proceeding. Staff has not received any complaints, formal or informal, from customers under
Schedule Nos. 7, 7A, or 11 in the last ten years. Since the majority of the amendments simply
institutionalize current Company practice or remove unpopular lighting options, Staff does not
believe the revisions are contentious by nature. Based on its findings, Staff recommends approving
Rocky Mountain Power's proposed adjustments.
STAFF RECOMMENDATION
Staff recommends the Commission approve Rocky Mountain Power's proposed revisions to
Schedule Nos. 7, 7A, 11 and Electric Service Regulation No. 12.
STAFF COMMENTS 3 MARCH 27, 2012
114
Respectfully submitted this day of March 2012.
p. $A Krstine A. Sasser
Deputy Attorney General
Technical Staff: Bryan Lanspery
i:umisc:comments/pace 11 ,4ksbl comments
STAFF COMMENTS 4 MARCH 27, 2012
PacifiCorp Lighting Options for
Schedule Nos. 7, 7A, and 11
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Lighting Option Schedule # Units, 2010 Change in Units
Since 2007
MV 7 1948 (277)
HPSV 7 992 (347)
HPS Flood 7 557 (6)
LPSV 7 0 0
MV 7A 1124 (223)
HPSV 7A 951 206
HPS Flood 7A 36 (12)
LPSV 7A 0 0
HPSV 11 2057 (203)
MH 11 0 0
MV: Mercury Vapor
HPSV: High Pressure Sodium Vapor
HPS Flood: High Pressure Sodium Flood
LPSV: Low Pressure Sodium Vapor
MH: Metal Halide
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 27 ' DAY OF MARCH 2012,
SERVED THE FOREGOING COMMENTS OF THE COMMISSION STAFF, IN CASE
NO, PAC-E-12-04, BY MAILING A COPY THEREOF, POSTAGE PREPAID, TO THE
FOLLOWING:
DANIEL E SOLANDER
TED WESTON
ROCKY MOUNTAIN POWER
201 S MAIN ST STE 2300
SALT LAKE CITY UT 84111
E-MAIL: [e-mail]
[e-mail]
DATA REQUEST RESPONSE CENTER
E-MAIL ONLY:
datareguestpacificorp.com
SECRETARY
CERTIFICATE OF SERVICE