20191018Decision Memo.pdf

DECISION MEMORANDUM
TO COMMISSIONER KJELLANDER
COMMISSIONER RAPER
COMMISSIONER ANDERSON
COMMISSION SECRETARY
COMMISSION STAFF
LEGAL
FROM:MATT HUNTER
DEPUTY ATTORNEY GENERAL
DATE: OCTOBER 18,2019
SUBJECT:APPLICATION OF ROCKY MOUNTAIN POWER FOR AUTHORITY TO
REVISE ELECTRIC SERVICE REGULATION NO. 4-,SUPPLY AND USE
OF SERVICE; CASE NO. PAC-E-19-14
On September 27,2019, Rocky Mountain Power (the Company) applied to the
Commission for an Order authorizing the Company to revise Electric Service Regulation No. 4-
Supply of Service, (Regulation 4) to allow unmetered service in certain instances for small usage
devices whose total connected load does not exceed 2 kilowatts (kW).
THE APPLICATION
The Company proposes a revised paragraph I of Regulation 4 to allow unmetered
service for "small usage devices": devices whose total connected load does not exceed 2 kW per
point of connection. Application at2. The Company states this revision solves a logistical problem
facing 4G and 5G cell antennas in dense commercial areas. 1d. Because of limited mounting space
and municipal ordinances, cell phone carriers struggle to mount meters for cell antennas. Id. After
hearing from cell phone carriers about this challenge, the Company proposed this revision to the
industry and received a very positive response. Id. at 3.
The proposed revision would provide for unmetered service if, at the sole discretion of
the Company, usage is impractical or unsafe to meter. Id. Unmetered service is subject to these
conditions: 1) the small usage device's load must not exceed two kW per point of connection;2)
all equipment must meet the Company's design and installation requirements; 3) the customer
service application must provide the small usage device's capacity requirements; 4) the Company
will calculate monthly usage of the small capacity device as the total capacity requirement of the
equipment multiplied by 730 hours (the number of hours in a month); 5) the Company may test
the capacity requirements of the small usage devices; and 6) the customer must give the Company
at least 30-days' notice before changing load. Id.
If the Company determines that the customer underreported capacity or otherwise
failed to notify the Company of its increased capacity, the Company may back-bill the customer
under Electric Service Regulation No. 8, section 6-Adjustment for Billing Error-for the
incremental kilowattftrour usage associated with the higher capacity. Application at 3. The
Company notes this "protects other customers and ensures that the risks of accepting un-metered
service in this limited situation are properly balanced." Id. If the customer makes changes that
make the service ineligible for unmetered service, Company-approved metering point(s) must be
installed by the customer within 30 days following notification from the Company that the service
is ineligible for unmetered service. Id. If Company-approved metering point(s) are not installed
within this time, service will be disconnected.Id.
The Company states that unmetered service for small usage devices will "benefit
customers and have minimal impact to Company operations." Application at 4. The Company
requests that its Application be processed under Modified Procedure, and that the Commission
approve the proposed changes with an effective date of January l,2O2O.Id.
STAFF RECOMMENDATION
Staff recommends the Commission issue a Notice of Application and Notice of
Modified Procedure setting a November 26,20L9 comment deadline, and a December 3,2019
reply deadline.
COMMISSION DECISION
Should the Commission issue a Notice of Application and Notice of Modified
Procedure setting a November 26, 2019 comment deadline, and a December 3, 2019 reply
deadline?
Matt Hunter
Deputy Attorney General
I:V-egal\ELECTRIC\PAC-E-1 9- l4Memos\PACEl914_mh (2).docx