20230808Objection to PacifiCorp Answer.pdf

RECEIVED
2023 AUGUST 8, 2023 8:00AM
IDAHO PUBLIC
UTILITIES COMMISSION
OBJECTION TO COMPANY'S ANSWER
To: Jan Noriyuki, Commission Secretary
Idaho Public Utilities Commission
PO Box 83720
Boise, ID 83 720-007 4
Date: August 7, 2023
From: Samuel and Peggy Edwards
333 Shoshone Ave
Rexburg, Idaho 83440
RE: Objection to Rocky Mountain Power's "Answer to Petition for Reconsideration", Idaho Public
Utilities Commission Final Order of Case TD "PAC-E-23-05"
Dear Ma'am,
I ask the Commission's indulgence for a brief summary note . ROCKY MOUNTAIN
POWER/PACIFICORP ("Company") has written an "Answer to Petition for Reconsideration"
which misconstrues my Petition as not complying with Rule 331 of the Rules of Procedure of the
Idaho Public Utilities Commission. The Company claims that I failed to "provide sufficient
reasoning as to why Order No. 35849 is unreasonable or unlawful, and the Petitioners have not
presented any new evidence ... "
In order to avoid confusion, I would briefly summarize that our Petition of July 28, 2023
offered new evidence that advanced metering infrastructure (AMI) meters include a capability
downgrade, that 100% compliance is unreasonable, arid that allowing ROCKY MOUNTAIN
POWER/PACIFICORP to disconnect our electric service is not lm1iful. My question regarding the
lawfulness of the Commission's order is grounded upon our objection to the Company's
replacement of our meter with an inferior metering technology, which is not a covered purpose for
meter access under Electric Service Regulation (ESR) 6(2)(d). Utility Customer Relations Rules
(UCRR) 302 defines the conditions for termination of Service and is not enforceable if the purpose
of Company access to the meter does not comply with ESR 6(2)(d). ESR 7(1), also cited in Order
No. 35849, applies to installation of meters, and the Company's responsibility to maintain the
meter cannot give the Company sole discretion to replace it with any technology (even inferior)
without Customer approval.
Please protect the minority of ROCKY MOUNTAIN POWER/PACIFICORP 's customers
and the public by reconsidering the lawfulness of your order that effectively mandates AMI meter
installations in Idaho.
Respectfully,
~~--E~i Juris