IPUC 2021 to 2024 Strategic Plan JUL2020.pdf

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STRATEGIC PLAN
Fiscal Years
2021 to 2024

Revised July 1, 2020
Our mission:
• Determine fair, just, reasonable and nondiscriminatory
rates and utility practices for electric, gas, telephone and
water consumers.
• Ensure the delivery of safe, reliable and efficient utility
services.
• Regulate the public utilities to secure and promote the
general safety, health and public welfare.
• Ensure safe operation of intrastate pipelines.
• Ensure the safe transportation of hazardous materials by
the railroads.
• Ensure the public safety at railroad grade crossings and
public streets, roads or highways.
• Implement and maintain a secure cyber network for the
staff and public.

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INTRODUCTION

The Idaho Public Utilities Commission (hereafter Commission) was established by the 12th session of
the Idaho Legislature and was organized on May 8, 1913. The Commission’s statutory authorities are
set out in Idaho Code, Titles 61 and 62.

The Commission oversees the intrastate operation of investor-owned electric, gas, water, and
telecommunications utilities. The Commission does not regulate publicly owned, municipal or
cooperative utilities. The Commission also does not regulate cable TV companies, cellular
telecommunication carriers or paging companies.

For much of the last 100 years, public utility regulation has been based on the theory of a “regulatory
compact” between utilities and regulators: In return for an exclusive franchise granted by regulators,
utilities agree to serve all those requesting service; and in return for agreeing to invest capital in plant
and facilities, utilities are given a reasonable opportunity to earn a fair return on that capital. Changes
in law and technology are dramatically affecting the industries we regulate, opening the door to more
competitors and enabling the establishment of more competitive markets.

The Commission also oversees rail and pipeline safety programs.

The Commission is actively pursuing to define and implement a secure cyber network modeled after
the National Institute and Technology Cybersecurity Framework.

MISSION STATEMENT

The Commission serves the citizens and utilities of Idaho by ensuring that the rates and policies
established for utility services are fair, just, reasonable and nondiscriminatory; utility services are
delivered safely, reliably, and efficiently; and pipelines and rail carriers operate safely within the state.

STRATEGIC PLAN

VISION: The Commission balances the interests of Idaho jurisdictional utilities and their
customers. The Commission is uniquely situated to act on behalf of public utility ratepayers in
establishing a proactive regulatory environment that encourages development and dispatch of
cost-effective energy resources in an increasingly changing environment. However,
implementing regulatory actions to accommodate the legitimate interests of both ratepayers and
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utilities requires a delicate balance between costs allowed for scientific advancements in
generation and costs to the Idaho economy. The Commission will continue to be proactive in the
areas of water and natural gas conservation.

ADMINISTRATION DIVISION

Program Goal:
The Administration Division is responsible for managing and coordinating the administrative activities
of the Commission efficiently and effectively. The Administration Division manages all information
received, handled or published by the Commission; it informs the public of its actions and decisions; it
maintains a website with an electronic database of Commission cases and other information; it
provides fiscal, personnel, information technology, and administrative support services to the
Commission as a whole; and it supports the Legislative and Executive branches with analysis and
information on utility, pipeline and railroad matters.

Program Objective 1 - Manage and coordinate the administrative activities of the Commission
efficiently and effectively as well as facilitate the efficient management of cases being considered by
the Commission.

Annual Performance Measures:
Number of cases older than a year that are closed during the fiscal year.
Annual Performance Targets:
Close 20% of all cases older than one year.
External Factors:
The Commission has no control over the number of cases filed. While it makes every effort to
close all cases in a timely manner, the judicial process requires adequate time for public
comment, discovery, investigation, presentation of evidence, receiving testimony and
deliberation.

UTILITIES DIVISION

Program Goal: Ensure that the citizens of Idaho are charged just, fair, reasonable and
nondiscriminatory rates for utility commodities and that utility services are delivered safely, reliably
and efficiently.
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Program Objective 1 – Perform audits and investigations of utilities for compliance with
Commission orders and regulations.

Annual Performance Measures:
Number of comprehensive audits completed.
Number of utility annual reports reviewed.
Annual Performance Target:
Conduct seven comprehensive audits of utilities.
Conduct 20 annual report reviews of utilities.
External Factors:
The Commission has no control over the number of rate cases filed in a fiscal year.
Funding and manpower limits the number of audits. The availability of qualified auditors,
engineers and analysts to fill personnel vacancies impacts operations. Reviews may
produce results requiring additional time and resources to resolve.

Program Objective 2 – Investigate and resolve complaints from customers. Respond to inquiries
regarding regulated utilities.

Annual Performance Measures:
Number of formal complaints received by Commission.
Number of informal complaints received by Commission.
Number of inquiries received by Commission.
Average number of days needed to respond to inquiries and resolve informal complaints.
Annual Performance Target:
Respond to inquiries and resolve informal complaints within an average of 10 business days.
External Factors:
The Commission has no control over the number of inquiries or complaints received in a fiscal
year. Funding for resources limits the number of investigators to handle inquiries and
complaints.

PIPELINE SAFETY SECTION
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Program Goal - Serve the citizens of Idaho by ensuring the safe transportation of natural gas shipped
in intrastate pipelines. This is accomplished by monitoring the compliance of jurisdictional operators
with state and federal regulations.

Program Objective 1 – Conduct on-site visits of gas system operators’ facilities and conduct audits
and inspections to ensure compliance with state and federal pipeline safety regulations.

Annual Performance Measures:
Number of inspection units audited.
Number of inspection days completed.
Annual Performance Targets:
14 inspection units audited.
275 inspection days completed.
External Factors:
Availability of funds, weather, and operator schedules.

Program Objective 2 – Conduct on-site inspections of gas system operator records, maintenance,
construction, training, integrity management, incident, operator qualification and damage prevention
activities to ensure all areas of natural gas transportation are conducted in a safe manner.
Annual Performance Measures:
Number of inspection types audited.
Annual Performance Targets:
Perform inspection of predetermined operational aspects of each operator each calendar year.
External Factors:
Availability of funds, weather, and operator schedules.

Program Objective 3 – Conduct follow-up investigation of all natural gas operator reportable
accidents and incidents to ensure corrective action is taken and the operator is in compliance with state
and federal regulations.

Annual Performance Measures:
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Number of reportable accidents and incidents.
Annual Performance Targets:
Conduct investigation follow-up of all reportable accidents and incidents.
External Factors:
Availability of funds, weather, and operator schedules.

RAIL SECTION

Program Goal - Serve the citizens of Idaho by ensuring that carriers comply with state and federal
safety regulations regarding crossings, clearances and the carriage of hazardous materials. The
Commission will also determine whether or not it is in the public interest to represent the state in
various rail line abandonment cases before the Surface Transportation Board.

Program Objective 1 - Inspect rail crossings and clearances for compliance with rules and regulations
based on complaints and accident investigations.

Annual Performance Measures:
Number of rail crossings and clearances inspected based on complaints, applications, and
accidents.
Annual Performance Targets:
Investigate all rail crossing complaints within 30 days, and accidents within 180 days
External Factors:
Number of complaints, number of accidents, availability of funds, weather, and operator
schedules.

CYBERSECURITY NETWORK

Program Goal – To work with the State’s cybersecurity task force to define and implement a
security framework modeled after the National Institute and Technology (NIST) Cybersecurity
Framework and the Center for Internet Security (CIS) Controls.
Program Objective 1 – Identify the necessary actions to be taken to ensure that the
Commission’s systems are in compliance with CIS controls.
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Annual Performance Measures:
Determine how many of the CIS’s first five controls are implemented.
Annual Performance Targets:
Implement the required security controls to be in compliance with the State’s
Cybersecurity Task Force Recommendations (E.O. 2017-02). Consolidate IT functions
within the Office of Information Technology implemented by July 1, 2019.

RED TAPE REDUCTION ACT
Program Goal – To comply with the Red Tape Reduction Act (Executive Order 2019-02), each
state agency is required to designate a Rules Review Officer (RRO) “to undertake a critical and
comprehensive review of the agency’s administrative rules to identify costly, ineffective, or
outdated regulations.”
Program Object 1 – Work with Commission Staff to identify rule sections that can be modified
or rule sections or chapters that can be eliminated, and make recommendations to the
Commission.
Annual Performance Measures– Progress must also be reported annually through the agency’s
performance report under the profile of cases managed. Currently the PUC has (see addendum):
▪ Number of Chapters of Administrative Code
o 13 Chapters
▪ Number of Words in Administrative Code (Excluding Table of Contents and Index)
o 7,7509 Words (10,191 reduction from 2019)
▪ Number of Restrictions in Administrative Code (Use of “shall,” “must,” “may not,”
“prohibited,” and “required.”)
o 892 Restrictive Words (374 reduction from 2019)
▪ Rules Review Officer Designee
o Stephen Goodson, Policy Advisor to the Commissioners

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ADDENDUM

Senior Commission Staff will do a more in depth review of the proposed rules that were posted
in the June Special Bulletin. The PUC Staff will host workshops with interested parties and
identify chapters or subsections of chapter.
The current total number of pages is 165 comprised of a total of 77,509 words with 892 words
which are restrictive in nature.

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Rules as of March 19, 2020
Rule Chapter Pages Words

Rules of Procedure 50 27068
Saftey and Accident Reporting 4 1416
Systems of Accounts for Public Utilities 2 792
Utility Customer Relations 19 9834
Energy Consumption 3 894

Master Metering 3 1215
Stray Voltage 29 9677

Gas Service 4 1389

Telephone Customer Relations 20 10617
Universal Service Fund 12 6239
Telecomunication Relay Services 8 3912
Operator Services and Pay Telephone 0 0
Automatic Dial and Announcemet Devices 0 0

Railroad Safety Rules (Combined with RR Saftey and Accident
Reporting 9 4316
Railroad Safety and Accident Reporting 0 0

Small Water Companies 2 140
Total (13 Chapters) 165 77509
11% 17%

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Pending Rules as of March 19, 2020
Rule Chapter
Shall Must
May
Not Prohibited Required
General Rules of Procedure 115 154 2 7 22
Saftey and Accident Reporting 3 4 0 2 12
Systems of Accounts for Public Utilities 0 0 0 0 5
Utility Customer Relations 11 21 0 4 21
Energy Consumption 2 2 0 0 0
Electric
Master Metering 0 2 1 2 0
Stray Voltage 184 6 0 0 13
Gas
Gas Service 27 1 0 0 1
Telephone
Telephone Customer Relations 19 52 0 0 28
Universal Service Fund 37 17 0 0 9
Telecomunication Relay Services 35 6 0 2 7
Operator Services and Pay Telephone 0 0 0 0 0

Automatic Dial and Announcement
Devices 0 0 0 0 0
Rail

Railroad Clearance (New Combined
Rule) 26 17 2 0 11
Railroad Safety and Accident Reporting 0 0 0 0 0
Water
Small Water Companies 0 0 0 0 0
Total 459 282 5 17 129 892
33% 16% 0% 50% 14% 26%