20190612Comments.pdf

EDWARD JEWELL
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 10446
RECEIVED
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ri-l i,l-{O PUSLIC'iit i,: -,; cOtil*tSSlCIN
Street Address for Express Mail:
472 W. WASHINGTON
BOISE, IDAHO 83702.5918
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION
OF ROCKY MOUNTAIN POWER FOR
AUTHORITY TO MODIFY SCHEDULE NO.
135 _ NET METERING SERVICE
CASE NO. PAC.E.19.O3
COMMENTS OF THE
COMMISSION STAFF
The Staff of the Idaho Public Utilities Commission comments as follows on Rocky
Mountain Power's Application.
BACKGROUND
On March 15,2019, Rocky Mountain Power ("Rocky Mountain" or "Company") 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 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.
If the Application is approved, customers could submit a written request to the Company
between March 1 and March 3 1 each year requesting the transfer of eligible credits. A $ l0
processing fee would apply to each meter receiving the excess energy credits.
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1STAFF COMMENTS JLINE 72,2019
The Company requested an effective date of May 15,2019. That date was suspended
until November 14, 2019, by Commission Order No. 34307.
STAFF ANALYSIS
With one exception, Staff supports the Company's proposal. Staff recommends a
definition of "contiguous parcels" be added to the Company's proposed Special Condition
No. 12, as further explained later in Staff s Comments. Staff notes that the Commission has
previously addressed the issue of allowing net metering customers of Idaho Power to transfer
excess credits. In Case No. IPC-E- 12-27 , Staff supported implementation of a process to transfer
excess net energy credits from a designated meter to offset usage on other meters, subject to
certain conditions. In Order No. 32925, the Commission found that net metering customers
should be allowed to:
... apply the customer's excess kWh credits from the designated
meter to offset usage recorded on aggregated meters if all of the
following eligibility criteria are satisfied:
I ) The customer may only apply the excess net energy credits to
accounts held by the customer;
2) The aggregated meters must be located on, or contiguous to, the
property on which the designated meter is located. Contiguous
property includes property that is separated from the premises of
the designated meter by public or railroad rights of way;
3) The designated meter and the aggregated meters must be served
by the same primary feeder; and
4) The electricity recorded by the designated meter and any
aggregated meters must be for the customer generator's
requirements.
See Order No. 32925 at 6.
In order to facilitate a review of all of Rocky Mountain's proposed changes to
Schedule 135, Staff has prepared a comparison of the Company's proposal to Idaho Power
Company's Tariff provisions as approved by the Commission. (See Attachment A).
TRANSFER OF FINANCIAL CREDITS
The Company requests approval of a process for transferring excess financial credits for
net metering customers. Staff is aware that the Company has transferred excess financial credits
between net metering customer accounts in the past, although there was no Commission-
2STAFF COMMENTS JUNE 12,2019
approved process for doing so for Rocky Mountain Power's customers. Staff commends the
Company for developing a proposal for the Commission's consideration.
Staff recommends the Commission adopt the Company's proposal to allow customers a
once per year transfer of financial credits to eligible meters that are served under the same rate
schedule. Staff believes the request for credit transfer between eligible meters that are served
under the same rate schedule is reasonable because it aligns with Order No. 32925, which states
that eligible meters include those owned by the same customer and within "schedules with
similar rates and rate designs." See Order No. 32925 at 8. Allowing the transfer of credits
between similar rate schedules mitigates a mismatch of energy credit value that can occur
between schedules with different rates. As previously noted by the Commission;
...fixed costs built into each unit of excess net energy may vary
when a credit is applied across schedules, and our intent with net
metering is to approach a one-to-one offset (i.e., the value of a
kWh generated is worth the same as a kWh credit used to offset
usage).
See Order No.32925 at7.
Staff acknowledges there is an administrative cost to transfer credits. Staff notes the
Commission approved a $10.00 processing fee per meter for Idaho Power in Order No. 32925
at 7. Staff recommends the Commission approve Rocky Mountain's request to charge customers
a $10.00 fee for eligible transfers.
CONTIGUOUS PARCELS
As proposed, Schedule 135 would be modified to state that credits may be transferred
between meter(s) that meet certain criteria, one of which is, "The meter is located on, or
contiguous to, the Premises on which the meter with excess financial credit are located." See
Rocky Mountain Power's Tariff, Sheet No. 135.3, Section l2.a.i. A different section of the
Company's Tariff, "Regulation 2," defines premises as follows:
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." See Rocky Mountain Power's Tariff, Electric Service
Regulation No. 2, Sheet No. 2R.3.
STAFF COMMENTS JUNE I2,2OI9J
Therefore, it is possible that the Company's Tariff could be construed to preclude transfer of
excess financial credits between meters on contiguous parcels that are located across an
easement. Staff believes it is appropriate for these customers to be able to transfer excess
financial credits between meters on contiguous properties, including houses separated by an
easement. 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.
In order to prevent confusion, Staff proposes addition of the following definition of
contiguous parcels to the Company's proposed Special Condition No. l2:
iv) For the purposes ofSchedule 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 recommends the Commission allow the Company to transfer financial credits on an
annual basis, and that the Company allow customers to make the transfer to contiguous parcels
as more clearly defined by Staff.
STAFF RECOMMENDATION
Staff recommends the Commission:
1. Approve the Company's request to allow net metering customers to transfer
financial credits on an annual basis. Customer requests are to be submitted by customers
between March 1 and March 31. The Company will complete the eligible transfers within thirty
days ofthe request.
2. Approve the transfer of financial credits between accounts belonging to the same
customer and served under the same rate schedule and on the same primary feeder.
3. Approve Staff s recommendation to revise Schedule 135 by including the definition of
contiguous properties as described in Staff comments, and thus allow the transfer of credits even
when properties are separated by an easement.
4. Approve the Company's request to charge a $10 fee to cover the administrative cost of
completing a transfer.
STAFF COMMENTS JLrNE 12,20194
Respectfully submitted this tz+*day ofJune 2019.
Edward
Deputy General
Technical Staff: Chris Hecht
Rachelle Farnsworth
Michael Morrison
i :umisc:comments/pace I 9.3ejcwhrfmm comments
5STAFF COMMENTS JUNE 12,2019
Comparison of IPC and RMP's Proposed
Excess Credit Transfer
Idaho Power Rocky Mountain
1
Customers are eligible to transfer credit if there
is excess energy credit at the end oftheir
December billing period.
Customers may request to transfer excess financial
credit at the end of their February billing period.
2
Credits shall remain on the account, and may
only be used to offset the Customer's energy
charges at the meter originating the credit or
other eligible meters. Accounts to be offset must
belong to the customer.
Same as Idaho Power
J
Meter to be offset must be located on, or
contiguous to, the property on which the
Designated Meter is located.
Contiguous property includes property that is
separated from the premises of the Designated
Meter by public or railroad rights of way.
Meter to be offset must be located on, or contiguous to,
the premises on which the meter with excess financial
credit is located.
Premises defined as 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.
4
The meter to be offset must be served by the
same primary feeder as the meter with excess
kWh credit (Designated Meter).
Both meters had to be in service at the time the
customer submitted their On-site Generation
Application
Meters eligible to transfer financial credit must be
served by the same primary feeder as the meter with
the excess financial credits.
5
Credit may only be transferred to meters taking
service under Schedule l, 6, 7 and 8, or between
meters served under Schedule 9, 19 and24.
Meters eligible to apply a transferred credit to must be
on the same rate schedule as the meter with the excess
financialcredit.
6
Customer must submit requests to transfer credit
before midnight MST on January 31.
Customers must submit written requests for credit
transfers between March I and March 31 of each year.
The Company must receive all requests by midnight
March 31.
7
The Company has until March 3l to execute
requests.
The Company will transfer financial credit 30 days
from the date the customer's request is received.
8
If a customer has multiple meters, credit will be
applied to the Designated Meter first, then to any
eligible meter on the same rate schedule, then to
other eligible meters on differing schedules.
Credit may be transferred to a meter or meters that
meet the Company's eligibility criteria.
9
There is a $ l0 meter aggregation fee due to the
difficulty of transferring kWh credits the current
billing system.
There is a $10.00 aggregation fee applied to each meter
receiving transferred credit.
Attachment A
Case No. PAC-E-19-03
staff comments
06t12119
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS I2TH DAY OF JUNE 2019,
SERVED THE FOREGOING COMMENTS OF THE COMMISSION STAFF, IN
CASE NO. PAC-E-19-03, BY MAILING A COPY THEREOF, POSTAGE PREPAID,
TO THE FOLLOWING:
TED WESTON
ROCKY MOUNTAIN POWER
1407 WEST NORTH TEMPLE STE 330
SALT LAKE CITY UT 84I16
E-MAIL : ted.weston@pacifi corp. corn
DATA REQUEST RESPONSE CENTER
E.MAIL ONLY:
datarequest@pacifi corp. com
DANIEL E SOLANDER
ROCKY MOUNTAIN POWER
1407 WN TEMPLE STE 320
SALT LAKE CITY UT 841I6
E-MAIL: [e-mail]
,lr , ,/'
SECRETARY
CERTIFICATE OF SERVTCE