20190910Idaho Power Comments.pdf

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LISA D. NORDSTROM
Lead Counsel
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September 10,2019
Ms. Diane Hanian
Secretary
ldaho Public Utilities Commission
PO Box 83720
Boise, lD 83720-0074
RE Case No. RUL-U-19-01
UPDATING THE IDAHO PUBLIC UTILITIES COMMISSION, UTILITY
CUSTOMER RELATIONS RULES
Dear Ms. Hanian:
ldaho Power Company ("ldaho Powed'or "Company") appreciates the opportunity to
comment on proposed changes to the ldaho Public Utilities Commission ("Commission"),
Utility Customer Relations Rules ('UCRR') (IDAPA 31.21.01). ldaho Power has conducted
a review of Commission Staffs recommended changes and supports the adoption of these
changes with the following modifications:
1. Staffs modification to UCRRs 201.02 and 208: Due to limitations of its current
billing system and statements, ldaho Power's existing system cannot
accommodate the degree day information requirement if this rule is relocated to
201.02a as recommended by Staff. The Company supports keeping this rule as a
stand-alone section and not included within the requirement for billing statements.
Alternatively, ldaho Power would also support removing this section in its entirety,
as ldaho Power does not receive many requests for degree day adjusted data.
2. Staff modification to UCRR 202.ldaho Power recommends the Commission retain
the language that Staff requested to be removed regarding the bill due date: "(or
twelve (12) days after mailing or delivery of paper or electronic bill, if bills are
mailed or delivered more than three (3) days after the [bill issuance datel]." This
language facilitates utility use of outside vendors to print customer bills more cost-
effectively than can be performed by the utility.
ldaho Power also proposes three minor modifications to the UCRRs for Staffs consideration
1. UCRR 302.01e: As a condition of service, customers typically grant utilities a right
of way for the facilities necessary to provide utility service. For instance, section 7
of ldaho Power's Rule C requires the customer to "grant the Company a right of
way for the Company's lines and apparatus across and upon the property owned
1 Staff proposed changing "billing date" to "bill issuance date", thus, ldaho Power maintained
change
ldaho Public Utilities Commission
September 10, 2019
Page 2
or controlled by the custome/' at no cost to the Company. To account for instances
where access is denied to utility facilities on the customer's property other than
meters (e.9., the service drop), ldaho Power recommends modifying the language
"meter'' to "utility's facilities":
The customer or applicant denied or willfully prevented the
utility's access to the meler utilitv's facilities.
2. UCRR 303.01 and 604.01: ldaho Power recommends adding "utility's rules and
regulations" to the grounds for denial or termination of service without prior notice:
Dangerous Conditions. A condition immediately dangerous or
hazardous to life, physical safety, or property exists, or if
necessary to prevent a violation of federal, state or local safety
or health codes, or utility rules and reoulations.
This language is consistent with the grounds for disconnecting utility service found
in Oregon Administrative Rule 860-021-0305(7) and facilitates immediate utility
action to preserve safe utility service to other customers (e.9., customer demand
spikes without notice in excess facilities' capacity to serve). This language also
provides utilities with the ability to prompt customers to timely resolve issues
involving customer-owned electrical facilities, or other conditions on the customer's
property, that are impairing or likely to impair service, create a hazardous
condition, or adversely affect the safe and reliable operation and maintenance of
the company's system (e.9., customer places foundation for residential addition in
a location that negatively impacts access to underground service line in violation
of utility's design requirements; ldaho Power design standards prohibit location of
swimming pools under service lines).
3. UCRR 306.01: lf the intent of the Winter Protection Plan's prohibition on
disconnecting service to vulnerable populations is to promote public safety while
minimizing uncollectible amounts in the spring, the Company requests language
to clarify that this protection exists "at the primary household" rather than to all
service points (which can include non-essential service to metered locations like
swimming pools and cabins) on the customer's account:
Restrictions on Termination of Service to Households with
Children, Elderly, or lnfirm. Except as provided in Rule 303, no
gas or electric utility may terminate service or threaten to
terminate service during the months of December through
February to any residential customer who declares that he or
she is unable to pay in full for utility service at the primarv
household and whose primary household includes children,
elderly or infirmed persons.
P.O. Box 70 (83707)
1221 W. ldaho St.
Boise, lD 83702
ldaho Public Utilities Commission
September'10, 2019
Page 2
ldaho Power has discussed the above recommendations with Rocky Mountain Power
and Avista Corporation ("Electric Utilities"). ldaho Power is not aware of any opposition by the
Electric Utilities to the above recommendations. If you have any questions regarding these
comments, please contact Regulatory Analyst Christina Zwainz at [phone] or
czw ainz@i d a h o powe r. com .
Very truly yours,
,1*-.9 l(-*l***'
Lisa D. Nordstrom
LDN/KKt
cc Linda Gervais, Avista Corp
Ted Weston, PacifiCorp
P.O. Box 70 (83707)
I22I W. ldaho St.
Boise, lD 83702