20190703final_order_no_34370.pdf

Office of the Secretary
Service Date
July 3,2019
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION )CASE NO.PAC-E-19-03
OF ROCKY MOUNTAIN POWER FOR )AUTHORITY TO MODIFY SCHEDULE NO.)
135 -NET METERING SERVICE )ORDER NO.34370
On March 15,2019,Rocky Mountain Power ("Rocky Mountain"or "Company")filed
an Applicationseeking approval of a modification to its Electric Service Schedule No.135 -Net
Metering Service ("Schedule No.135").
On April 8,2019,the Commission issued a Notice of Application,Notice of
Suspension of Proposed Effective Date,and Notice of Modified Procedure.Order No.34307.
Now,after reviewing the record,the Commission approves the Application with
modification.
BACKGROUND AND APPLICATION
The Company established Schedule No.135 for its Idaho customers in 2003.Order
No.29260.Under Schedule No.135,a customer can net consumption and generationon a monthly
basis.If,after a month,the customer has generated more energy than the customer has consumed
during the month,the customer is awarded a financial credit for the net excess energy contributed
to the grid.
The Company seeks to add Special Condition number 12 to Schedule No.135,which
would allow customers to transfer financial credits once per year between meters that are owned
by the same customer and located on the same or contiguous premises as the meter with excess
financial credits,so long as the meters are served by the same primary feeder and are on the same
rate schedule.Under the proposed Special Condition number 12,customers could submit a written
request to the Company between March 16'and March 316'each year requesting the transfer of
eligible credits.A $10 processing fee would apply to each meter receiving the excess energy
credits.
COMMENTS
a.Comments of Commission Staff
Staff supports approval of the Application,with one exception.Staff recommends a
definition of "contiguous parcels"be added to the Company's Tariff in order to more clearly define
ORDER NO.34370 1
which meters are on "contiguous"parcels of land.Staff proposes allowing credits to be transferred
between meters on property separated by a public thoroughfare.Staff's proposed language is:
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 considered contiguous but are
divided by an easement for a dedicated street,highway or other
public thoroughfare,or railway.
Staff believes it is appropriate for customers to be able to transfer excess financial credits between
meters on property separated by a public right of way.
Staff's concern about transferring credits to otherwise contiguous property across a
public thoroughfare derives from the Company's use of Regulation 2 in its Application to define
"premises."See Application at 3.Regulation 2 states,"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."Rocky Mountain Power's Tariff,Electric
Service Regulation No.2,Sheet No.2R.3.Staff states,"Regulation No.2 pertains to the
Company's distribution system and the provision of electric service to customers in general,but it
is irrelevant to the matter of transferring financial credits for net metering customers."Staff
Comments at 4.
b.Public Comment.
One member of the public filed a comment and stated that net metering customers
should be able to transfer any credits they accrue.
c.Reply Comments of Rocky Mountain Power.
The Company does not support Staff's recommendation to add its proposed definition
of contiguous parcels.The Company states that some land for dedicated streets is provided by
easement,but other land is provided by deed,or some other type of conveyance.Reply Comments
of Rocky Mountain Power at 2.The Company believes that determining eligibilityto transfer
credits should not depend on the type of conveyance that created the public right of way between
properties.The Company states it "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."Id
The Company supports a more circumscribed eligibilityfor credit transfer based on its
read of language in Schedule 135,which states,"To qualify,a Customer must maintain its retail
ORDER NO.34370 2
electric service account for the loads served at the Point of Delivery adjacent to the Generation
Interconnection Point as active and in good standing (formattingin Reply Comments of Rocky
Mountain Power at 2)."The Company states,"Meter aggregation in theory allows customers to
'wheel'their generation from one point of delivery to another utilizingthe Company's grid at no
cost."Id
COMMISSION FINDINGS AND DECISION
The Commission has jurisdiction over this matter under Idaho Code §§61-502 and 61-
503.The Commission is empowered to investigate rates,charges,rules,regulations,practices,
and contracts of public utilities and to determine whether they are just,reasonable,preferential,
discriminatory,or in violation of any provision of law,and to fix the same by order.Idaho Code §§
61-502 and 61-503.
The Commission has reviewed the record and approves the Company's Application,
with modification.The Commission believes Staff's recommendation to allow the transfer of
excess net energy credits to property separated by a public thoroughfare is reasonable,though we
will use the term "public right of way."The Company did not explain how the aggregation of
meters across a public right of way is materially different from aggregationof meters on adjoining
parcels of land.
The Company states that meter aggregation increases the Company's under-recovery
of fixed costs,and therefore customers should not be allowed to aggregate meters across a public
right of way.Yet the underlying request in the Company's Application is to allow for the
aggregation of meters.The Company has presented no evidence that there is greater under-
recovery of costs to aggregate meters located across a public right of way from each other than
there is for meters on adjoining parcels of land.The Company asserts that meter aggregation
allows customers to wheel their generation from one meter to another without paying for the
additional use of the Company's electric system.Again,the Company does not distinguish
between meters located across a public right of way from one another and meters on adjoining
parcels of land.
The Company's point that Staff's specific reference to an easement could cause
unnecessary confusion and present an arbitrary distinction between meters eligible to aggregate
and those meters not eligible to aggregate is well taken.Therefore,we revise Staff's proposed
wording of Special Condition number 12 to read:
ORDER NO.34370 3
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 considered contiguous but are
divided by a public right of way.
We intend the term "public right of way"to broadly include,but not be limited to,streets,
highways,railroads,and easements,and to not depend on the type of conveyance that created the
public right of way.
Finally,we note that allowingtransfer of excess net energy credits between meters on
contiguous property,as recommended by Staff to include parcels separated by a public right of
way,aligns meter aggregationunder Schedule No.135 closely with Idaho Power's Schedule No.
84.While we do not mandate that programs between utilities be identical,the similarity here
demonstrates that the policy can be effectivelyimplemented and managed.Consequently,we find
these modifications to Schedule No.135 to be just and reasonable.
ORDER
IT IS HEREBY ORDERED that the Company's Application is approved,subject to
the modification described herein.
THIS IS A FINAL ORDER.Any person interested in this Order may petition for
reconsideration within twenty-one (21)days of the service date of this Order with regard to any
matter decided in this Order.Within seven (7)days after any person has petitioned for
reconsideration,any other person may cross-petition for reconsideration.See Idaho Code §61-
626.
ORDER NO.34370 4
DONE by Order of the Idaho Public Utilities Commission at Boise,Idaho this 9
day of July2019.
PAUË KJELLANDÈ PRESIDENT
KRI NE RAPER,COMMISSIONER
ERIC ANDERSON,COMMISSIONER
ATTEST:
Diane M.Hanian
Commission Secretary
1:\Legal\ELECTRIC\PAC-E-19-03\PACE1903_final order_ej
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