20221122Decision Memo.pdf

DECISION MEMORANDUM 1

DECISION MEMORANDUM

TO: COMMISSIONER ANDERSON
COMMISSIONER CHATBURN
COMMISSIONER HAMMOND
COMMISSION SECRETARY
COMMISSION STAFF
LEGAL

FROM: CLAIRE SHARP
DEPUTY ATTORNEY GENERAL

DATE: NOVEMBER 22, 2022

SUBJECT: IN THE MATTER OF ROCKY MOUNTAIN POWER’S APPLICATION
FOR AUTHORITY TO IMPLEMENT THE RESIDENTIAL RATE
MODERNIZATION PLAN; PAC-E-22-15.

On October 20, 2022, PacifiCorp d/b/a Rocky Mountain Power (“Company”), applied for
authority to implement a residential rate modernization plan over a five-year transition period
(“Residential Rate Modernization Plan”). Application at 1. The Company proposes to modify
residential rates by: (1) increasing the Customer Service Charge for both Electric Service Schedule
No. 1 – Residential Service (“Schedule 1”) and Electric Service Schedule No. 36 – Optional time
of Day – Residential Service (“Schedule 36”) to $29.25 per month, and lower the variable energy
charge (“Energy Charge”) commensurately; (2) eliminate inclining block tiered rates for Schedule
1; and (3) changing the time of use periods in Schedule 36 to be consistent with the on- and off-
peak periods listed in electric Service Schedule No. 9-General Service (“Schedule 9”). Id. at 2.
On November 9, 2022, the Company filed an errata to its Application (“Errata to
Application”) that corrects the proposed rates depicted in the Tables 5 and 6 of Robert Meredith’s
direct testimony so they are reflected as cents per kilowatt-hour (“¢/kWh”) as opposed to dollars
per kWh.
The Company requested that the Commission issue an order: (1) authorizing that the
Application be processed by Modified Procedure; and (2) Approving the implementation of the
Residential Rate Modernization Plan, effective December 1, 2022.

DECISION MEMORANDUM 2

BACKGROUND
The Company’s current residential rate structure includes a monthly fixed charge
(“Customer Service Charge”) and a variable Energy Charge based on usage. Application at 3. The
Company argues that the Customer Service Charge does not cover its fixed costs to serve
customers, and that customers have instead been covering those fixed costs through the variable
Energy Charge. Id. at 3-4. The Company proposes to increase the current $8 per month Customer
Service Charge to $29.95 per month over five years. Id. at 2; Application Exhibit 2.
For Residential Schedule 1 customers, the Company’s Energy Charge Summer Season
rates would decrease from the present 11.1966¢/kWh to 8.6574¢/kWh (first tier) and from
13.0999¢/kWh to 8.6574¢/kWh (second tier) over five years. Errata to Application at Meredith
Testimony 15-16. For Residential Schedule 1 customers, the Company’s Energy Charge Winter
Rates would decrease from 9.3305¢/kWh (first tier) to 7.2145¢/kWh and from 10.9165¢/kWh to
7.2145¢/kWh (second tier) over five years. Id.
For Schedule 36, Time-of-Use residential customers, the Company’s Summer Season on-
peak energy rate would decrease from 15.2201¢/kWh to 14.7738¢/kWh and the off-peak rate
would decrease from 5.3672¢/kWh to 4.7423¢ over five years. Id. For Schedule 36 customers, the
Winter Season on-peak rates would decrease from 13.0395¢/kWh to 12.6572¢ and off-peak rates
would decrease from 4.9346¢/kWh to 4.3600¢/kWh over five years. Id.
STAFF RECOMMENDATION
Staff recommends the Commission issue a Notice of Application, Notice of Intervention
Deadline establishing a 21-day intervention period, and Notice of Suspension suspending the
Company’s proposed effective date.
COMMISSION DECISION
Does the Commission wish to issue a Notice of Application, a Notice of Intervention
Deadline establishing a 21-day intervention period, and Notice of Suspension suspending the
Company’s proposed effective date?

Claire Sharp
Deputy Attorney General

I:\Legal\ELECTRIC\PAC-E-22-15 Res Mod Plan\memos\PACE2215_dec_cs.docx