950210.docx

DECISION MEMORANDUM
TO:COMMISSIONER SMITH
COMMISSIONER NELSON
COMMISSIONER HANSEN
MYRNA WALTERS
TONYA CLARK
STEPHANIE MILLER
DAVID SCHUNKE
DON HOWELL
RICK STERLING
BEVERLY BARKER
GARY RICHARDSON
WORKING FILE
FROM:SCOTT WOODBURY
DATE:FEBRUARY 10, 1995
RE:CASE NO. UPL-E-95-1
SCHEDULE 10—IRRIGATION PUMPING SERVICE
On December 13(21), 1994  PacifiCorp dba Utah Power & Light Company (Utah Power; UP&L) filed proposed changes to its irrigation and soil drainage pumping power service tariff sheets with the Idaho Public Utilities Commission (Commission).  Reference IPUC–No. 28 Electric Service Schedule No. 10—Connection and Disconnection Charges.  The Company requested a January 13, 1995 effective date.
UP&L currently disconnects customers at the end of the irrigation season and reconnects them each spring.  The company proposes to keep irrigation customers connected year round unless the customer requests disconnection in writing. The company will continue its policy of giving customers one free disconnection and reconnection each year. Customers will not be billed during the winter months, when usage will be non-existent or minimal. The initial spring bill will reflect any energy usage during the winter months.
The Company states the following reasons for making this change:
Historically, the Company has disconnected irrigation pumping service during the winter to reduce electrical losses associated with unloaded, energized transformers. However we have found a higher incidence of failure among transformers that are not energized during the post-season. The increased cost of transformer failure offset the savings resulting from reduced losses when the transformers are not energized. As the routine disconnection and reconnection of irrigation pumps once a year is very time consuming and costly, eliminating this practice will result in a net savings in operating expenses.
After reviewing the Company’s Application the Commission made the preliminary finding that the issues presented were appropriate for processing under Modified Procedure, i.e., by written submission rather than by hearing. Reference IDAPA 31.01.01.201 et seq.  Commission Notices of Application and Modified Procedure in Case No. UPL-E-95-1 issued on January 10, 1995.  The deadline for filing written comments or protests with respect to the Company’s Application and the use of Modified Procedure was January 31, 1995.  The Commission suspended the Company’s proposed effective date by Order No. 25854 pending further procedure and Order.
Commission Staff was the only party to submit written comments.  (attached).  Staff acknowledges the benefits of the Company’s proposal.  Staff addresses safety concerns related to the remoteness of meter, panel and pump motor installation sites, exposure to elements, animals and rodents, language barriers, and need for periodic maintenance and cleaning.  Staff makes the following recommendations:  
1.UP&L should implement a campaign to educate irrigation customers about the change.  This could include bill inserts, letters and media advertising.
2.Stickers should be attached to the front of pump panels (and also inside if possible) with a message stating that the panel is always energized.  The message should appear in both English and Spanish.
3.UP&L should periodically visually inspect irrigation services.  The inspection should include equipment between the Company's meter and the customer's pump, as well as equipment on the Company's side of the meter.  While the customer is ultimately responsible for the safety of their own equipment, it would be irresponsible for the Company to re-energize equipment with obvious safety problems.
4.UP&L should record and report any electrical accidents that occur during the non-irrigation season.  This would alert the Company if safety is actually a problem.
5.Customers should be able to request disconnection  for the entire non-irrigation season or for any part of it for purposes of making inspections or repairs.  There should be no charge for one disconnection and reconnection, and customers should be able to request disconnection either orally or in writing.
Commission Decision:
Should the Company’s Application be approved?  Should approval be subject to compliance with Staff recommendations?

Scott Woodbury
vld/M-UPL-E-95-1.sw