20191126Comments.pdf

MATT HTINTER
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-007 4
[phone]
IDAHO BARNO. 10655
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25 Al'tll: l5
I
'i.; {J r,i i,,le SIC Il
Street Address for Express Mail:
1 1331 W CHINDEN BVLD, BLDG 8, SUITE 20I.A
BOISE, ID 83714
Attomey for the Commission Stal'f
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF ROCKY MOUNTAIN
POWER'S APPLICATION TO RXVISE
ELECTRIC SERVICE REGULATION NO. 4 -
SUPPLY AND USE, OF SERVICE
CASE NO. PAC.E.I9-I4
COMMENTS OF THE
COMMISSION STAFF
STAFF OF the Idaho Public Utilities Commission, by and through its Attorney of
record, Matt Hunter, Deputy Attomey General, submits the following comments.
BACKGROUND
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 Company proposed a revised paragraph 1 of Regulation 4 to allow unmetered service
for "small usage devices": devices whose total connected load does not exceed 2 kW per point of
corurection. The proposed revision would provide for unmetered service if, at the sole discretion
of the Company, usage is impractical or unsafe to meter.
The Company stated this revision solves a logistical problem facing 4G and 5G cell
antennas in dense commercial areas. Because of limited mounting space and municipal
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NOVEMBDR 26,2019ISTAFF COMMENTS
ordinances, cell phone carriers struggle to mount meters for cell antennas. After hearing fiom
cell phone carriers about this challenge, the Company discussed with them its plan to propose a
new unmetered service option for Commission approval. The Company indicated that the
carriers strongly supported the plans.
Rocky Mountain Power requested that its Application be processed under Modified
Procedure with a proposed cff'ective date ofJanuary 1,2020.
2S'I'AFF COMMENTS NOVEMBER 26,2019
STAFF ANALYSIS
Staff recommends that the Commission approve the Company's proposal to allow
unmetered service in certain instances for small usage devices whose total connected load does
not exceed 2 kW. This enlails authorizing the Company to revise Electric Service Regulation
No. 4-Supply of Service, (Regulation 4). Stafl s recommendation is based on its review of the
Company's Application and the responses to production requests. Staff agrees with the
Company's claim that implementing unmetered service for small usage devices will benefit
customers and have minimal impacl on Company operations. Cost ofservice is reduced through
eliminating unnecessary metering costs and customer service is enhanced.
Under the proposal, unmetered service would be subject to these conditions: l) the small
usage device's load must not exceed 2 kW per point ofconnection; 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 ofthe small capacity device as the total capacity requirement of the equipment multiplied
by 730 hours (the number ofhours 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.
If the Company determines that the customer underreported capacity or otherwise failed
to notily 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 incremcntal
kilowatL/hour usage associated with the higher capacity. The Company notes this "protects other
customers and ensures that the risks ofaccepting un-metered service in this limited situation are
properly balanced."
Ifthe 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. If
Company-approved metering point(s) are not installed within this time, service will be
disconnected.
The proposed unmetered service shall be billed under Electric Service Schedule 23
(General Service) with the customer's monthly bill for a single point of delivery based on kWh
usage determined by the connected load. Monthly energy use shall be specified in the service
agreement associated with the delivery point. The monthly bill for a specific delivery point
remains flat over time because connected load remains constant.
STAF'F' RE,COMMENDATION
Staff recommends that the Commission approve the Company's proposal to revise
Electric Service Regulation No. zl--Supply of Service, (Regulation 4). This will allow the
Company to implement unmetered service in certain instances for small usage devices whose
total connected load does not exceed 2 kW. Staff recommends an effective date of
January 1,2020.
-ARespectfully submitted this )f -duy ofNovember20l9.
Matl I Iunter
Deputy Attomey General
Technical Staff: Travis Culbertson
Michael Eldred
Bentley Erdwurm
i:umisc/oomments/paccl9. l4mhhcmebc commcnls
lSTAFF COMMENTS NOVEMBER 26, 20I9
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 26th DAY OF NOVEMBER 2019,
SERVED THE FOREGOING COMMENTS OF THE COMMISSION STAFF, IN CASE
NO. PAC-E.19-I4, BY MAILING A COPY THEREOF, POSTAGE PREPAID, TO THE
FOLLOWING:
DATA REQUEST RESPONSE CENTER
E.MAIL ONLY:
d atarequest(g)paci licorp.c om
S
CERTIFICATE OF SERVICE
TED WESTON
ROCKYMOUNTAIN POWER
1407 WN TEMPLE STE 330
SALT LAKE CITY UT 84116
E-MAIL: ted.weston@pacifi corp.com
DANIEL E SOLANDER
SENIOR COLTNSEL
ROCKY MOLTNTAIN POWER
I4O7 WN TEMPLE STE 320
SALT LAKE CITY U]'84I I6
E-MAIL: daniel.solandcr@oaci fi corp.com