20200115Comments.pdf

JOHN R. HAMMOND, JR.
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720.0074
[phone]
IDAHO BAR NO,5470
RECEIVED
1020 JllN l5 At{ 9: h7
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Street Address for Express Mail:
I1331 W CHINDEN BLVD, BLDG 8, SUITE 2OI.A
BOISE, ID 83714
Attomey lbr the Commission Staff
BEFORE THE IDAHO PUBLIC UTILTTIES COMMISSION
IN THE MATTER OF ROCKY MOUNTAIN
POWER'S APPLICATION TO MODIFY
ELECTRIC SERVICE SCHEDULE NO.3I
PARTIAL REQUIREMENTS SERVICE
CASE NO. PAC.E.I9-15
COMMENTS OF THE
COMMISSION STAFF
COMES NOW the Staff of the Idaho Public Utilities Commission, by and through its
attorney of record, John R. Hammond, Jr., Deputy Attomey General, and in response to the
Notice of Application and Modified Procedure issued in Order No,34477 on November 8, 2019,
in Case No. PAC-E-I9-15, submits the lollowing comments.
BACKGROT]ND
On October 10, 2019, PacifiCorp dba Rocky Mountain Power ("Rocky Mountain" or
"Company") frled an Application requesting the Commission approve modifications to its Electric
Service Schedule No. 31, Partial Requirements Service - High Voltage C'Partial Requirements
Service"), to add an option for customers taking service at distribution voltage levels. The
Company requested that its Application be processed by Modified Procedure.
In December 2012, the Commission approved Schedule No. 31, Partial Requirements
Service for customers taking service at transmission voltage levels. See Order No. 32704.
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STAFF COMMENTS JANUARY I5.2O2OI
Application at 2. Partial Rcquirements Service is designed to provide Supplementary, Back-up,
Maintenance, or Excess Power service lor customers with onsite generation.
Partial Requirements Servioe is currently only available to transmission customers with
loads up to 15,000 kW. However, the Company has been contacted by a customer that takes
service at a distribution level voltage who is interested in Partial Requirements Service. -Id. at 3.
Rocky Mountain requests Commission authority to expand Schedulc No. 3 I to make
partial requirements service available to customers servcd at distribution voltages. The Company
believes this will also provide more transparency for customers to better evaluate their options as
they consider self-generation. 1d.
The Company proposes to add two additional rates to Schedule No. 3 I , l) Secondary
Service for customers taking service under 2300 volts; and 2) Primary Service tbr distribution
service ol'2300 volts or higher.
STAFF'ANALYSIS
Staffrecommends that the Commission approve the Company's request to add primary
and secondary distribution level sen'ice to Electric Service Schedule No. 31. Staffbased its
recommendation on two factors. First, Stalfbelieves that expanding this service allows a broader
range of customers the opportunity to self'-generate. Second, Staff determined that the proposed
ratcs should cover the cost of the service. Consequcntly, implementation of the proposed ratcs
will not shift costs to the Company's other customers.
By expanding partial requirements service, the Company avoids discriminating against
Customers who wish to self-generate, but only have access 1o distribution level service.
Customers considering self-generation as a viable option may require access to back-up,
maintenance, or supplementary service to cover equipment outages or energy needs in excess of
their self-generation capabilities.
Staffexpects no adverse impact to the Company's other customers by expanding this
service to customers that request it. Stal'f verilied that the method used to calculate the current
partial requirement Schedule No. 3 I rates lbr high voltage transmission customers was the same
method the Company used to calculate the rates for this proposal. To calculate the current partial
requirement rates lor transmission level customers authorized through Order No. 32704. the
Company identified the applicable costs needed to sen'e Partial Requirements Service t'rom thc
1STAFF COMMENTS JANUARY 15,2O2O
costs needed to serve full requirement service under Schedule No. 9, General Service - High
Voltage. Similarly, the partial requirement rates for distribution level customers under this
proposal were based on costs needed to serve full requirement service under Electric Service
Schedule No. 6, General Service - Large Pou,cr. All partial requirement rates, proposed and
cunent, are based upon the Company's most recently filed cost of service study in Case No.
PAC-E-11-12. Application at 3-4.
STAFF RECOMMENDATION
Staff recommends that the Commission approve Rocky Mountain's proposed Electric
Service Schedule No. 31. Partial Requirements Service, tariff sheets provided as Attachment B of
the Application, which include partial requirements rates for Secondary Service lor customers
taking service under 2300 volts; and Primary Service for distribution service of2300 volts or
higher.
Respectfully submitted this
lr-
day ofJanuary 2020.
IIammond, Jr.
Attorne.v General
Technical Staff: Rick Keller
Bentley Erdwurm
Brad Iverson-Long
irumisorcommenls/pace 19. I 5jhrkblbe comments
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-)STAFF COMMENTS JANUARY 15,2O2O
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CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS I5,].H DAY OF JANUARY 2020,
SERVED THE FOREGOING COMMENTS OF THE COMMISSION STAFF', IN
CASE NO. PAC.E-I9-15, BY MAILING A COPY THEREOF, POSTAGE PREPAID,
TO THE FOLLOWING:
TED WESTON
ROCKY MOLINTAIN POWER
I4O7 WN TEMPLE STE 330
SALT LAKE CITY UT 84116
E-MAIL: ted.weston(Apacifi corp.com
DATA REQUEST R-ESPONSE CENTER
E-MAIL ONLY:
datarequest@.pacifi corp.com
DANIEL E SOLANDER
SENIOR COLTNSEL
ROCKY MOL-TNTAIN POWER
I4O7 WN TEMPLE STE 320
SALT LAKE CITY UT 84I I6
E-MAIL: [e-mail]
SECRETAR
CERTIFICATE OF SERVICE