20190619Reply Comments.pdf

Y ROCKY MOUNTAIN
FOWER
A OTV|STON OF mCTFTCORP
Vice
REC EIVED
?$l9 JUil l9 ffl ll: l7 1407 West North Temple, Suite 330
Salt Lake City, Utah 84116
June 19,2019
VA OWRNIGHT DELIVERY
lDi\l"itl PUBLIC
r'1" I l. iT i i:S COMI'{lSSl0N
Diane Hanian
Commission Secretary
Idaho Public Utilities Commission
472W. Washington
Boise, D 83702
Re:CASE NO. PAC.E"I9-03
IN THE MATTER OF TIIE APPLICATION OF ROCKY MOUNTAIN POWER
FOR AUTHORITY TO MODIF"T SCIMDULE NO. 135I\TET METERING
SERVICE
Dear Ms. Hanian:
Please find enclosed an original and seven (7) copies of Rocky Mountain Power's Reply
Comments in the above referenced matter.
Informal inquiries may be directed to Ted Weston, Idaho Regulatory Manager at (801) 220-
2963.
Very truly yours,
"^*D
Daniel E. Solander (ISB No. 8931)
1407 W. North Temple, Suite 320
Salt Lake City, Utah 84116
Telephone No. [phone]
E-mail: [e-mail]
Attorneyfor Rocky Mountain Power
BEFORE TIIE IDAIIO PUBLIC UTILITTES COM]VtrSSION
RECEIVED
?019 JUll t9 AH il: t8
r T, Ll? flisjj$Yfrh l8r, o*
IN TIIE MATTER OF TIIE
APPLICATION OF ROCI(Y MOUNTAIN
POWER FOR AUTHORITY TO MODIT"Y
SCIMDULE NO. 135 - I\TET METERING
SERYICE
CASE NO. PAC.E-19.03
REPLY COMMENTS OF
ROCI(Y MOTINTAIN POWER
PacifiCorp, d.b.a. Rocky Mountain Power ("Rocky Mountain Power" or "Company"),
hereby provides its Reply Comments to the Comments of Staff for the Idaho Public Utilities
Commission ("Staff') in the above-captioned Case.
1. On March 15,2019, Rocky Mountain Power filed an Application seeking approval
of a modification to its Electric Service Schedule No. 135 - Net Metering Service ("Schedule
No. 135") to allow customers to transfer excess financial credits once per year if the meters are:
(1) owned by the same customer; (2) located on the same premises or contiguous to the premises
on which the meter with excess financial credits is located; (3) served by the same primary feeder;
and (a) on the same rate schedule.
2. On June 12,2019, Staff provided Comments on the Application. Staff supports the
Company's proposal, but noted it is possible that the Company's proposed tariff could be construed
to preclude transfer of excess financial credits between meters on contiguous parcels that are
divided by an easement.
I
3. Accordingly, Staff proposed that the following definition of contiguous parcels be
added to the Company's proposed Special Condition No. 12:
iv) For the purposes of Schedule 135, parcels shall be considered contiguous if they share
a common boundary or corner, and includes parcels that would otherwise be contiguous
but are divided by an easement for a dedicated steet, highway or other public thoroughfare,
or railway.
4. The Company does not support Staff s proposed modifications to the definition to
include easements. The Company believes this addition adds ambiguity, provides opportunity for
gamesmanship and could create uncertainty. The land for some dedicated streets is provided for
by way of easement, and others by deed. Making the distinction adds ambiguity of whether a given
steet is provided for by easement or deed, or possibly some other conveyance. The Company
thoughtfully selected "premises" for the tariff language because it is an existing definition in
Rule 2, it is easily understood and clearly defines what can be included. The Company's existing
Premise language does not require this distinction:
"Premises: All of the real property and apparatus employed in a single enterprise on an
integral parcel of land undivided by a dedicated street, highway or other public
thoroughfare, or railway."
5. Eligible generating plant is defined in Electric Service Schedule 1 35 - Net Metering
Services as : "To qualify, a Customer must maintain its retail electic service account for the loads
served at the Point of Delivery adjacent to the Generation Interconnection Point as active and
in good standing." Net metering is intended to offset a customer's own usage without utilizing
Company owned resources. Meter aggregation in theory allows customers to oowheel" their
generation from one point of delivery to another utilizing the Company's grid at no cost.
6. Approximately 73.9 percent of the costs to serve residential customers are
essentially fixed costs for recovery of operations and investments already made to serve customers,
2
only 7.8 percent of those costs are recovered through fixed charges. Therefore, approximately
89 percent of the fixed cost recovery is subject to the customer's volumetric kilowatt-hour usage.
The Company under-collects, relative to the cost of senrice, approximately $378 per year from
residential customers and approximately $651 per year from Schedule 23 customers on the current
net metering program. Customer aggregation increases the under-recovery of fixed costs and shifts
those costs to other customers.
REQUEST FOR RELIEF
WHEREFORE, Rocky Mountain Power respectfully requests that the Commission
approve the Company's Application to modiff Schedule No. 135 - Net Metering Service as filed
without modification.
DATED this 19ft day of June, 2019.
RESPECTFTJLLY SUBMITTED,
ROCKY MOT]NTAIN POWER
4,fih
Daniel E. Solander
aJ