20200910Exception Comments.pdf

Salt Lake City, Utah 84116
September 10, 2020
VIA ELECTRONIC FILING
Jan Noriyuki
Commission Secretary
Idaho Public Utilities Commission
11331 W. Chinden Blvd.
Building 8 Suite 201A
Boise, ID 83714
Re: CASE NO. PAC-E-19-08
IN THE MATTER OF THE APPLICATION OF ROCKY MOUNTAIN POWER
TO CLOSE THE NET METERING PROGRAM TO NEW SERVICE &
IMPLEMENT A NET BILLING PROGRAM TO COMPENSATE CUSTOMER
GENERATORS FOR EXPORTED GENERATION
Dear Ms. Noriyuki:
Please find an electronic filing of Rocky Mountain Power’s Exception Comments in the above
referenced matter.
Informal inquiries may be directed to Ted Weston, Idaho Regulatory Manager at (801) 220-
2963.
Very truly yours,
Joelle Steward
Vice President, Regulation
1407 West North Temple, Suite 330
RECEIVED
September 10, 2020 9:56:18 AM
IDAHO PUBLIC
UTILITIES COMMISSION

1
Emily Wegener
1407 West North Temple, Suite 320
Salt Lake City, Utah 84116
Telephone No. [phone]
Mobile No. [phone]
Email: [e-mail]
Attorney for Rocky Mountain Power
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION
OF ROCKY MOUNTAIN POWER TO
CLOSE THE NET METERING PROGRAM
TO NEW SERVICE & IMPLEMENT A NET
BILLING PROGRAM TO COMPENSATE
CUSTOMER GENERATORS FOR
EXPORTED GENERATION
)
) CASE NO. PAC-E-19-08
)
) EXCEPTION COMMENTS OF
) ROCKY MOUNTAIN POWER
)
)
Pursuant to Order No. 347521 issued by the Idaho Public Utilities Commission
(“Commission”) on August 26, 2020, Rocky Mountain Power a division of PacifiCorp (the
“Company”) hereby submits exception comments in the above-referenced matter.
I. BACKGROUND
1. On August 26, 2020, the Commission issued a “Proposed” Order granting
grandfathering for customers on Electric Service Schedule No. 135 – Net Metering Service.
The Commission also proposed to approve the Company’s request to open Electric Service
Schedule No. 136 – Net Billing Service, as of October 1, 2020.

1 In the Matter of the Application of Rocky Mountain Power to Close the Net Metering program to New Service
& Implement a Net Billing Program to Compensate Customer Generators for Exported Generation, Proposed
Order on Grandfathering Order No. 34752.

2
II. EXCEPTION COMMENTS
2. In the Company’s original Application it requested one month between the
closure of Schedule 135 on December 31, 2019 before offering Schedule 136 February 1, 2020,
to provide sufficient time to make the necessary modifications to its billing system.
3. In Order 34752 the Commission “proposes” to approve Schedule 136 effective
October 1, 2020. The Company requests the same one month delay between the closure date
of Schedule 135 and initial offering of Schedule 136 to allow the Company time to update its
billing system.
III. REQUEST FOR RELIEF
Rocky Mountain Power respectfully requests that when the Commission issues its final
order it provides the Company one month from the closure date of Schedule 135 before
offering Schedule 136.

DATED this 10th day of September, 2020.

Respectfully submitted,
ROCKY MOUNTAIN POWER

__________________________
Emily Wegener
1407 West North Temple, Suite 320
Salt Lake City, Utah 84116
Telephone No. [phone]
Mobile No. [phone]
Email: [e-mail]
Attorney for Rocky Mountain Power
Page 1 of 2
CERTIFICATE OF SERVICE
I hereby certify that on this 10th of September, 2020, I caused to be served, via electronic mail a true and correct copy of Rocky Mountain Power’s Exception Comments in Case No. PAC-E-19-08 to the following:

Service List

Idaho Irrigation Pumpers Association, Inc.
Eric L. Olsen
ECHO HAWK & OLSEN, PLLC
505 Pershing Ave., Ste. 100
P.O. Box 6119
Pocatello, Idaho 83205
[e-mail]

Anthony Yankel
12700 Lake Avenue, Unit 2505
Lakewood, Ohio 44107
[e-mail]

Idaho Conservation League
Benjamin J. Otto
Idaho Conservation League
710 N. 6th Street
Boise, Idaho 83702
[e-mail]

Idaho Clean Energy Association, Inc.
Preston N. Carter
Givens Pursley LLP
601 W. Bannock Street
Boise, ID 83702
[e-mail]
[e-mail]

Commission Staff
Edward Jewell
Deputy Attorney General
Idaho Public Utilities Commission
11331 W. Chinden Blvd., Bldg No. 8,
Suite 201-A
PO Box 83720
Boise, ID 83720-0074
[e-mail]

Page 2 of 2
Rocky Mountain Power
Ted Weston Rocky Mountain Power 1407 West North Temple, Suite 320 Salt Lake City, Utah 84116 [e-mail]

Data Request Response Center
PacifiCorp
825 NE Multnomah, Suite 2000
Portland, OR 97232
[e-mail]

Emily Wegene
Rocky Mountain Power
1407 West North Temple, Suite 320
Salt Lake City, Utah 84116
[e-mail]

Adam Lowney
McDowell Rackner Gibson PC
[e-mail]

Dated this 10th day of September, 2020.

__________________________________
Katie Savarin
Coordinator, Regulatory Operations