HomeMy WebLinkAbout20231017Decision Memo.pdfDECISION MEMORANDUM 1
DECISION MEMORANDUM
TO: COMMISSIONER ANDERSON
COMMISSIONER HAMMOND
COMMISSIONER LODGE
COMMISSION SECRETARY
COMMISSION STAFF
LEGAL
FROM: DAYN HARDIE
DEPUTY ATTORNEY GENERAL
DATE: OCTOBER 17, 2023
SUBJECT: IN THE MATTER OF ROCKY MOUNTAIN POWER’S PROPOSED
CHANGES TO ELECTRIC SERVICE REGULATION NO. 12, TARIFF
ADVICE NO. PAC-TAE-23-01.
On October 3, 2023, PacifiCorp dba Rocky Mountain Power (“Company”), filed a
Tariff Advice proposing changes to its Electric Service Regulation No. 12—Line Extensions
(“Regulation No. 12”), effective January 1, 2024. The Company cited concerns with service
requests from prospective large customers with loads that may never fully materialize. As it stands,
prospective large customers are eligible for an allowance up to nine times the estimated monthly
revenue generated from the customer under Regulation No. 12. The Company is concerned that
large projects eligible for the allowance necessitate upfront investment, but the projects may never
be fully built out leaving the Company with stranded, expensive infrastructure investments that
would not be offset from revenue generated from the customer, as anticipated. This situation would
leave other customers to pay for the investments.
To avoid the type of harm described above, the Company proposes to add part 3(b) to
Regulation No. 12 to limit allowances for customers whose service requirements exceed 25,000
kilovolt-amperes. The Company’s proposal would limit the allowance to the “cost of metering
equipment necessary to measure the Customer’s usage.” Tariff Advice at 2. For customers who
entered a master electric service agreement (“MESA”) with the Company prior to October 3, 2023,
the Company proposes to provide the allowance according to the terms of the MESA. For those
customers who have received a written estimate of the line extension allowance prior to October
3, 2023, but have not yet executed a MESA with the Company, the Company proposes to give
DECISION MEMORANDUM 2
those customers six months from the filing date to execute a MESA to receive the allowances
included in the estimate. Any requests made after October 3, 2023, would be subject to the updated
Regulation No. 12.
STAFF RECOMMENDATION
After reviewing the Company’s Tariff Advice, Staff believes a more formal process is
necessary to allow for participation by those who might be affected by the proposed changes. Staff
recommends the Commission treat the Tariff Advice as an Application by assigning a case number
and issue a Notice of Application and Notice of Intervention setting a 21-day intervention deadline.
COMMISSION DECISION
Does the Commission wish to issue a Notice of Application and set a 21-day
intervention deadline?
_____________________________
Dayn Hardie
Deputy Attorney General
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