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HomeMy WebLinkAbout20160422Reply Comments.pdf-ROCKY MOUNTAIN ,"rr,ai-,1,r... l40Tw.Northremple,suite3l0 YHSfiiER'!rYYr! r^rr- ilECtlVLU Sartlakecity,utarr-84u6 \ e ovrstorn op mcrrrconp ?01$ A;)R 22 Pl-l 2: Str ; '.'r!r,-j i:i-l ,_:i_if,Apil22'2016 rr rii, : cll,ii,iigsroil VA HAND DELIWRY Idaho Public Service Commission 472 W - Washington Street P.O. Box 83720 Boise, Idalro 83720-007 4 Auention: Jean D. Jewell Commission Secretary RE: CASE NO. PAC-E-16-06 IN THE MATTER OF THE APPLICATION OF ROCKY MOUNTAIN POWER FOR AUTHORITY TO MODIFY REGULATION NO. 9 - DEPOSITS AND ADVANCE PAYMENTS. Please find enclosed the original and seven (7) copies of Rocky Mountain Power's Reply Comments. Please contact Ted Weston directly at (801) 220-2963 if you have any further questions. Sincerely, J l,tt'1/rt P lrrrl"-/d.-- Jeffrey K. Larsen Vice President, Regulation Enclosures Yvonne R. Hogle (ISB#8930) 1407 W. North Temple, Suite 320 Salt Lake City UT 84116 Telephone: (801) 220-4050 FAX: (801)220-461s Email : yvonne.hoele@f'acifi corp.com Attorneyfor Rocky Mountain Power IN THE MATTER OF THE APPLICATION OF ROCKY MOUNTAIN POWER FOR AUTHORITY TO MODIFY REGT'LATION NO. 9 DEPOSITS AND ADVANCE PAYMENTS I{ECEiVED it]l6,lilli ZA pll Z: S+ i'-1: " 'l:;;',:l-lCi,..: ; __ i,i,'rli;ll$SI0;{ BEFORE TIIE IDAIIO PUBLIC UTILITIES COMMISSION CASE NO. PAC-E.T6.06 REPLY COMMENTS Rocky Mountain Power, a division of PacifiCorp ('the Company''), respectfully submits the following Reply Comments in response to comments filed by the Idaho Public Utilities Commission ("Commission") Staff ("Staff') on April 15, 2016.In these Reply Comments, Rocky Mountain Power clarifies certain sections of Electric Service Regulation No. 9 - Deposits and Advance Payments, as recommended by Staff and provides an explanation why the Commission should reject certain of Staffs other recommendations. BACKGROUND l. On February 16,2016, Rocky Mountain Power submitted an application to the Commission for authority to modify Electric Service Regulation No. 9 - Deposits and Advance Payments ("Application"). 2. On April 15,2016, Staff filed comments and recommended approval of the proposed changes to Regulation No. 9 with modifications. Specifically, Staff recommended that the Commission: (1) deny the Company's proposal to "require an REPLY COMMENTS OF ROCKY MOUNTAIN POWER. I advance payment for first time applicants"; (2) require the Company to clariff the language in Regulation No. 9 to explain (i) how the customer advance is calculated, (ii) criteria to quali$ as a guarantor, and (iii) when a deposit may be required; and (3) eliminate the requirement for deposits for customers that paid an advance the prior season and whose balance was less than $1,000 by December 3l't ofthat year. COMPANY RESPONSE 3. First, StafPs recommendation ignores that Regulation No. 9 already authorizes the Company to require an advance for first time irrigation customers. Subpart (c) of Section I states: "The Company may require a deposit or an advance payment from current and prospective industrial or large commercial customers or may require an advance payment from irrigation customers for the reasons stated in (b) above." (emphasis added) Subpart (b) specifies that an advance maybe required "when the applicant is applying for service for the first time from the Company." (emphasis added) The Company's application did not request approval for the Company, at its discretion, to require an advance payment from first time customers because Regulation 9 currently provides that option. The Company has successfully utilized advances to minimize customer risk and StafPs request to eliminate customer advances for new customers should be rejected. 4. The Company worked with the Idaho Irrigation Pumper Association, (*IIPA"), and agreed to add an option for a guarantor for both customer advances and deposits to remove any financial burden to new and existing customers while establishing their credit-worthiness. REPLY COMMENTS OF ROCKY MOUNTAIN POWER - 2 5. [n response to Staff s recommendation for the Company to clariff how it would calculate advance payments, the Company proposes the following language be added to Regulation 9 under the "lrrigation Advances Subpart D" section: The advance will be equal to the estimated monthly billings for the upcoming irrigation season, based upon the previous 12 months of metered usage at each service point. If the previous 12 months includes inactivity the estimate may include earlier periods. 6. In response to StafPs recommendation that Regulation 9 specify the qualifications of a guarantor, the Company proposes the following additions under the "Irrigation Advances and Irrigation Deposits, Subpart B.2" section: A guarantor must be: (i) an active Rocky Mountain Power Schedule 10 customer; (ii) larger or comparable in size based on previous year's metered services; and (iii) current on all accounts at the time of the application with no more than one past due notice in the previous twelve months. 7. Staff recommended that the lower limit for customer deposits be raised from $50.00 to $1,000.00 to be consistent with Idaho Power's threshold forrequiring a customer deposit. The Company does not require a deposit based on any certain dollar threshold. The Application proposed a dollar threshold whereby the Company would be allowed to require a customer advance. Tariff Sheet 9.R2, Subpart D - Irigation Customers, specifies that an advance may be required: "if the customer had a cumulative past due balance equal to or greater than $25,000 on December 31." 8. Under the Company's proposal, there would be only two situations whereby an irrigation customer may be required to pay a deposit before service is provided: (l) if the customer received two or more past due notices for non-payment of Schedule 10 service during the most recent irrigation season orthe last 12 month period during which service was received; or (2) if the Schedule 10 customer was required to REPLY COMMENTS OF ROCKY MOUNTAIN POWER.3 pay an advance for the previous irrigation season and the balance on December 31 was less than 525,000. The Company recommends that all customers required to pay an advance should be required to pay a deposit the following year to help establish payment history and demonstrate credit worthiness. Thus, there is no need to raise the lower limit for customer deposits from $50.00 to $1,000.00 to be consistent with Idaho Power's threshold for requiring a customer deposit. CONCLUSION Rocky Mountain Power appreciates StafPs comments and has made an effort to clarift how it would calculate a customer advance and to describe the criteria that it would use to determine if a guarantor is acceptable to the Company. With respect to Staffs remaining recommendations, for the reasons set forth above, the Company respectfully requests that the Commission reject them. The Company provided revised tariff sheets incorporating the clarifications with its Reply Comments and respectfully requests that the Commission approve them as filed. DATED this22n day of April,2016. Respectfully submifted, Ad.sa REPLY COMMENTS OF ROCKY MOUNTAIN POWER - 4 V,ROCKYMOUNTAINYpowee \ l orvrsror or PAcrFrcoRP I.P.U.C. No. I First Revision of Sheet No. 9R2 Canceling Original Sheet No.9R2 (b)Small Commercial Customers An applicant may be required to pay a deposit as a condition of service for the reasons stated in (a) above, or additionally, when the applicant is applying for service for the first time from the Company. (c) Industrial and Large Commercial The Company may require a deposit from current and prospective industrial or large commercial customers for the reasons stated in (b) above, or additionally: (1) The customer fails to pay the account on or before the date such payment is delinquent. (2) The nature of the customer's operation is extremely speculative or subject to a high probability of failure. (d) Irrigation Customers The Company may require a deposit or advance from past, current, and prospective irrigation, (Schedule 10), customers prior to providing electric service as follows: (1) Irrigation Advance A. An advance may be required from current, previous, or prospective Schedule l0 customers prior to providing electric service: The advance for each metered service point will be equal to the estimated monthly billings for the upcoming irrigation season based on the previous 12 months of metered usage at the location. If the previous 12 month metered usage includes inactivity during the inigation season, the estimate may include earlier time periods: L If the customer had a cumulative past due balance equal to or greater than $25,000 on December 31; 2. If the customer had service disconnected for nonpayment during the last four (4) years; 3. If at any time the customer sought any form of relief under the Federal Bankruptcy Laws, or has been discharged from bankruptcy, or whose receivership proceeding has been terminated, or whose bankruptcy proceedings have been dismissed; or 4. If the applicant is requesting service for the first time. B. As an altemative to payment an advance may be satisfied by: l. A guarantee of payment from a bank or financial institution acceptable to the Company; or 2. A guarantor acceptable to the Company. Submitted Under Case No. PAC-E-16-06 ISSUED: February 16,2016 EFFECTM: May 16,2016 ROCKY MOUNTAIN ng,,yYEn*, I.P.U.C. No. 1 Second Revision of Sheet No.9R3 Canceling First Revision of Sheet No. 9R3 (1)Irrigation Advance (continued) C. The customer may be required to pay an advance on all Schedule l0 accounts for which the customer is financially responsible and requesting service. D. The advance will be equal to the estimated monthly billings for the upcoming irrigation season, based upon the previous 12 months of metered usage at each service point. If the previous 12 months includes inactivity the estimate may include earlier periods. l. A portion of the advance will be applied to satisfy each monthly bill until the advance is depleted. Irrigation Deposit A. A deposit may be required from a current or previous Schedule 10 customer prior to providing electric service : 1. If the customer received two (2) or more past due notices for non-payment of Schedule l0 service during the most recent inigation season or the last 12 month period during which service was received; or 2. If the Schedule l0 customer was required to pay an advance for the previous inigation season and the balance on December 31 was less than $25,000. B. As an altemative to payment a deposit may be satisfied by: 1. A guarantee ofpayment from a bank or financial institution acceptable to the Company; or 2. A guarantor acceptable to the Company. C. A Schedule l0 customer that meets the requirements for payment of a deposit may be required to pay a deposit for each Schedule l0 account for which the customer is financially responsible and requesting service. D. The deposit for each metered service point is equal to the estimated monthly bill for the two highest months of usage within the last two (2) inigation seasons. The deposit must be paid before the Company will provide electric service. (3) Irrigation Advance or Deposit Guarantor A. A guarantor must be: (i) an active Rocky Mountain Power Schedule 10 customer; (ii) larger or comparable in size based on previous year's metered services; and (iii) (2) Submitted Under Case No. PAC-E-I6-06 ISSUED: February 16, 2016 EFFECTM: May 16,2016 Yffi#,^HNIOUNTAIN I.P.U.C. No. I First Revision of Sheet No.9R4 Canceling Original Sheet No.9R4 2. 3. 4. current on all accounts at the time of the application with no more than one past due notice in the previous twelve months. BANKRUPT CUSTOMERS Ifan applicant for service or a customer has sought any form ofreliefunder the Federal Bankruptcy Laws, has been brought within the jurisdiction of the bankruptcy court for any reason in an involuntary manner, or has had a receiver appointed in a state court proceeding, then a deposit or advance may be required as a condition of service. EXPLANATION OF DENIAL OF SERVICE OR REQUIREMENT OF DEPOSIT If the Company denies service or requires a deposit as a condition of providing service, then it must immediately provide an explanation regarding the reason for the deposit or denial of service. If service is currently being provided to the premises occupied by an applicant, the Company shall provide written notice of its refusal to serve. AMOUNT OF DEPOSIT A deposit required as a condition of service shall not exceed one-sixth of the Company's estimate of annual billings for residential and small commercial customers. For industrial and large commercial customers, deposits shall not exceed two (2) months of the Company's estimated peak billings. The Company shall advise the customer or applicant that the deposit may be paid in two (2) equal installments with the first installment paid at the time of application and the second installment paid in one (l) month. INTEREST ON DEPOSITS Interest on deposits held by the Company shall be accrued at the rate established annually by the order of the Idaho Public Utilities Commission. Interest shall be computed from the time the deposit is made until it is returned or applied to the bill. Interest will not accrue on a deposit if service is terminated temporarily at the request of a customer who leaves the deposit with the Company for future use as a deposit or if service has been permanently terminated and the Company has been unsuccessful in its attempt to refund a deposit. RETURN OF DEPOSIT (a)Existing Residential and Small Commercial Customers If the customer has paid all undisputed bills and has no more than one (l) late payment during the past twelve (12) consecutive months of service, the Company shall promptly return the deposit (with accrued interest) by either crediting the customer's current account or issuing a refund. Irrigation Customers If the customer has paid all undisputed bills and has no more than one (l) past due notice during the past twelve (12) month period during which service was received, 6. (b) Submitted Under Case No. PAC-E-16-06 ISSUED: February 16,2016 EFFECTM: May 16,2016 v,.RocKY MOUNTAIN-(POWER \ A DrvrsroN oF PActFtcoRP I.P.U.C. No. I Original Sheet No.9R5 the Company shall promptly retum the deposit (with accrued interest) by either crediting the customer's current account or issuing a refund. (c) Former Customers Upon termination of service, the deposit, with accrued interest, shall be credited to the final bill. The balance of the deposit remaining, if any, shall be returned promptly to the Customer. 6. RETURN OF DEPOSIT Retention During Dispute The Company may withhold the release of the deposit pending the resolution of a dispute. For residential and small commercial customers, interest will be paid for the entire period over which the deposit was held. For industrial, large commercial and irrigation customers, the Company will continue to pay interest if the resolution is in the customer's favor. TRANSFER OF DEPOSIT A Deposit, less any outstanding balance, shall be transferable and applicable for service to the same customer at a new location within the Company's service area. Deposits shall not be transferred from one customer to another customer or between classes of service. RECEIPT FORDEPOSIT When payment of a deposit is made, a receipt shall be furnished to each applicant or customer for the amount deposited. RETURN OF IRRIGATION ADVANCE PAYMENTS Any customer advance remaining at the end of the irrigation season will first be applied to any required deposit for the upcoming season before being refunded to the customer. Upon customer request, the Company will conduct an in-season review of the actual electric consumption and associated advance payment. The company may refund at the customer's request the portion of the advance in excess of the revised usage estimate for the remainder ofthat season. LARGER OR NEW DEPOSITS AND IRRIGATION ADVAITCES Nothing in this regulation shall prevent the Company from requiring a deposit or advance or a larger deposit or advance from existing customers in conformity with the standards set forth in this regulation. Should a larger or new deposit or advance be required, the reason therefor shall be specified in writing to the customer. Submitted Under Case No. PAC-E-16-06 ISSUED: May 16,2016 (d) 7. 8. 9. 10. EFFECTIVE:May 16,2016 YH,ffiF*HI,OUNTAIN I.P.U.C. No.1 First Revision of Sheet No. 9R.2 Canceling Original Sheet No.9R2 (b) Small Commercial Customers An applicant may be required to pay a deposit as a condition of service for the reasons stated in (a) above, or additionally, when the applicant is applying for service for the first time from the Company. (c) Industrialg$LargeCommercial@ The Company may require a deposit or an advance payment from current and prospective industrial or large commercial customers or may require an advance payment from irrigation customers for the reasons stated in (b) above, or additionally: (1) The g€ustomer fails to pay the account on or before the date such payment is delinquent. @ Fer rcasenal servi ing year (3)-The nature of the geustomer's operation is extremely speculative or subject to a high probability of failure.(d) Irrisation Customers The Company mav require a deposit or advance from past" current. and prospective irrieation. (Schedule l0). customers prior to providing electric service as follows: (1) Irrieation Advance A. An advance may be required from current. previous. or prospective Schedule l0 customers prior to providing electric service. The advance for each metered service pqint will be equal to the estimated monthly billings for the upcoming irrigation season based on the previous 12 months of metered usage at the location. If the previous 12 month metered usage includes inactivitv during the irrigation season. the estimate may include earlier time periods: 1. If the customer had a cumulative past due balance equal to or greater than $25.000 on December 31: 2. If the customer had service disconnected for nonpayment during the last four (4) vears: 3. If at any time the customer sought any form of relief under the Federal Bankruptcy Laws. or has been discharged from bankruptcy. or whose receivership proceeding has been terminated. or whose bankruptcy proceedings have been dismissed: or 4. If the applicant is requesting service for the first time. B. As an altemative to payment an advance may be satisfied by: Submitted Under +aviee+e*e{aw No. 06e6P.t\C-E- L5-iQ6 ISSUED: EFFECTIVE:@ -ROCKYMOUNTAINYpowee\ A DIVTSION Of PACIFICORP I.P.U.C. No. I First Revision of Sheet No. 9R.2 Canceline Original Sheet No.9R.2 1. A guarantee ofpayment from a bank or financial institution acceptable to the Company: or2. A guarantor acceptable to the Company. If an apptieant fer se t awsr nas Ueen Ureu in-"n @iee' immediately previde an explanatien regarding the reasen fer the depesit er denial ef serviee, If pre+i (Continued) Submitted Under A.dviee+e*ercase No. 0646PAC-E- 1 6-06 ISSUED:EFFECTM:@ vRocKYMOUNTAINx(PowER \ A OTVTS|ON Of PACTFICORP I.P.U.C. No. I SecondFirst Revision of Sheet No. 9R3 Canceling @Sheet No. 9R3 (l) Irrieation Advance (continued) C. The customer may be reouired to pav an advance on all Schedule 10 accounts for which the customer is financially responsible and requesting service. D. The advance will be equal to the estimated monthly billines for the upcoming irrigation season. based upon the previous 12 months of metered usage at each service point. If the previous l2 months includes inactivitv the estimate may include earlier periods. l. A Lortion of the advance will be applied to satis0 each monthlv bill until the advance is depleted. (2) Irrieation Denosit A. A deposit may be required from a current or previous Schedule l0 customer prior to providing electric service: l. If the customer received two (2) or more past due notices for non-payment of Schedule l0 service during the most recent irrigation season or the last 12 month period during which service was received: or 2. If the Schedule l0 customer was required to pay an advance for the previous irrigation season and the balance on December 3l was less than $25.000. B. As an altemative to payment a deposit may be satisfied by: l. A suarantee of payment from a bank or financial institution acceptable to the Company: or 2. A guarantor acceotable to the Company. C. A Schedule l0 customer that meets the requirements for payment of a deposit may be required to pav a deposit for each Schedule l0 account for which the customer is financially responsible and requesting service. D. The deposit for each metered service point is equal to the estimated monthly bill for the two highest months of usage within the last two (2) irrigation seasons. The deposit must be paid before the Company will provide electric service. (3) Irrigation Advance or Deposit Guarantor A. A guarantor must be: (i) an active Rocky Mountain Power Schedule l0 customer: (ii) larger or comparable in size based on previous year's metered services: and (iii) current on all accounts at the time of the application with no more than one past due notice in the previous twelve months. Submitted Under,4dvie+tetterCasg No. 0944PAGE:15-06 ISSUED: EFFECTIVE:@ v,RocKYMOUNTAIN-(POWER \ A OTVTSTON OF PACIFICORP I.P.U.C. No. I SecondFirst Revision of Sheet No. 9R3 Canceling @Sheet No. 9R3 2. BANKRUPTCUSTOMERS If an applicant for service or a customer has sought any form of relief under the Federal Bankruptcy Laws. has been brought within the iurisdiction of the bankruptcy court for any reason in an involuntary manner. or has had a receiver appointed in a state court proceeding. then a deposit or advance may be required as a condition of service. 4. AMEUNT EF DEPOSIT l\ depesit required as a eenditien ef serviee shall net exeeed ene sixth ef the €ernpany's estimate ef inone{+)-men+U is maee untit it is r terminated temperarily at the request ef a Custemer whe leaves the depesit-wittrthe-eernpany for If the €ustemer has paid all-undisputedbills and has ne mere than ene (1) late payment er-issuing-+refi*n* @ Upen terminatien ef serviee; the depesit; rvith aeerued interest; shall be eredited te the final Custeme+ Fer residential an the eempany rvill eentinue te ^ay interest if tl'e reselutien is in the eustemer's faver, Submitted Under Adviee4e+tedaSg No. 09O4PAQ i:16-Q6 ISSUED: EFFECTIVE:@ v,RocKYMOUNTAIN-(POWER \ A DrvrsroN oF PAoFtcoRP LP.U.C. No.l SecondFirst Revision of Sheet No.9R3 Canceling @Sheet No. 9R3 €ontinuC) Submitted Under Ad,vie+LetterCase No. O+O4PAC-E- I 6-06 ISSUED: EFFECTIVE:@ YH-M*HIVIOUNTAIN I.P.U.C. No. I Original Sheet No.9R4 current on all accounts at the time of the apolication with no more than one past due. notice in the previous twelve months. 2. BANKRUPT CUSTOMERS If an applicant for service or a customer has sought an-v form of relief under the Federal Bankruptcy Laws. has been brought within the jurisdiction of the bankruotcy court for any reason in an involuntary manner. or has had a receiver appointed in a state court proceedins. then a deposit or advance may be required as a condition of service. 3. EXPLANATION OF DENIAL OF SERVICE OR REOUIREMENT OF DEPOSIT If the Compan), denies service or requires a deposit as a condition of providing service. then it must immediately provide an explanation regardine the reason for the deposit or denial of service. If service is currently being provided to the premises occuoied by an applicant. the Company shall orovide written notice of its refusal to serve. 4. AMOUNT OF DEPOSIT A deposit required as a condition of service shall not exceed one-sixth of the Company's estimate of annual billings for residential and small commercial customers. For industrial and large commercial customers. deposits shall not exceed two (2) months of the Company's estimated peak billings. The Companv shall advise the customer or applicant that the deposit may be paid in two (2) equal installments with the first installment paid at the time of application and the second installment paid in one (l) month. 5. INTEREST ON DEPOSITS Interest on deposits held by the Company shall be accrued at the rate established annually by the order of the Idaho Public Utilities Commission. Interest shall be computed from the time the deposit is made until it is returned or applied to the bill. Interest will not accrue on a deposit if service is terminated temporarily at the request of a customer who leaves the deposit with the Comnany for future use as a deposit or if service has been permanently terminated and the Company has been unsuccessful in its attempt to refund a deposit. 6. RETURN OF DEPOSIT (a) Existine Residential and Small Commercial Customers If the customer has pirid all undisputed bills and has no more than one (l) late payment during the past twelve (12) consecutive months of service. the Company shall promptly return the deposit (with accrued interest) by either crediting the customer's current account or issuine a refund. (b) Irrieation Customers If the customer has paid all undisputed bills and has no more than one (1.) past due notice durins the past twelve (12) month period durins which service was received. F; I nun Submitted Under Advier+e*dase No. 0#6PAC- E- I 6-06 ISSUED:EFFECTIVE:@ vRocKYMOUNTAINx(PowER \ A DTV|S|ON Of PACIFICORP I.P.U.C. No. I Original Sheet No.9R4 the Company shall promptly retum the deposit (with accrued interest) by either creditinq the customer's current account or issuing a refund. (c) Former Customers Upon termination of service. the deposit. with accrued interest. shall be credited to the final bill. The balance of the deposit remaining. if any. shall be returned promptly to the Customer. (Continued)-@ 7- TR/INSFER eF DEPOSIT l\ Depesitr less any o frem ene etrstemer te anether eustemer er between elasses ef serviee, When payment ef a depesit is made; a reeeipt shall be fumished te eaeh applieant er eustemer fer th€€m€un+d€posid 9- ADVANCE PAYMENTS y\n aevanee payment may U the-eusteme+ Nethine in this reg is Submitted Under +aviee+e+e{ase No. 06-06PAtC-E:1l5-t06 ISSUED: EFFECTIVE:@ v,RocKYMOUNTAIN-(POWER \ A OrVrSrOt{ OF AAOFICORP I.P.U.C. No. I Original Sheet No.9R4 Submitted Under Adniee{,e#efeasg No. 06-06PAGE:Lt5:06 ISSUED: EFFECTIVE:@ v,RocKY MOUNTAINx(PowER \ A DTVTSTON Of PACTFTCORP I.P.U.C. No.l Original Sheet No.9R5 the Company shall promptly return the deposit (with accrued interest) by either crediting the customer's current account or issuing a refund. (c) Former Customers Upon termination of service. the denosit. with accrued interest. shall be credited to the final bill. The balance of the deposit remaining. if any. shall be retumed promptly to the Customer. 6. RETURN OF DEPOSIT (d) Retention Durine Disoute The Company may withhold the release of the deposit pendine the resolution of a dispute. For residential and small commercial customers. interest will be paid for the entire period over which the deposit was held. For industrial" larse commercial and irrisation customers. the Companv will continue to pay interest if the resolution is in the customer's favor. 7. TRANSFER OF DEPOSIT A Deposit. less any outstanding balance. shall be transferable and applicable for service to the same customer at a new location within the Company's service area. Deposits shall not be transferred from one customer to another customer or between classes of service. 8. RECEIPT FOR DEPOSIT When payment of a deposit is made. a receipt shall be furnished to each applicant or customer for the amount deposited. 9. RETURN OF IRRIGATION ADVANCE PAYMENTS Any customer advance remainine at the end of the irrieation season will first be applied to any required deposit for the upcoming season before being refunded to the customer. Upon customer request. the Company will conduct an in-season review of the actual electric consumption and associated advance payment. The company may refund at the customer's request the portion of the advance in excess of the revised usaqe estimate for the remainder ofthat season. 10. LARGER OR NEW DEPOSITS AND IRRIGATION ADVANCES Nothing in this regulation shall prevent the Company from requiring a deposit or advance or a larger deposit or advance from existing customers in conformitv with the standards set forth in this regulation. Should a larger or new deposit or advance be required. the reason therefor shall be specified in writing to the customer. Submitted Under Case No. PAC-E-16-06 ISSUED: May 16,2016 EFFECTIVE:May 16,2016