20071024PacifiCorp comments.pdf

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October 24, 2007 \DArjO Jj.4lt,~,..\C'..Q i O\V,N\i;J0'-
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VIA OVERNIGHT DELIVERY
Idaho Public Utilities Commission
472 West Washington
Boise, ill 83702-5983
Attention:Jean Jewell
Commission Secretary
Re: Docket No. 31-2101-0701
Case No. RUL-U-07-
Dear Ms, Jewell:
Rocky Mountain Power would like to thank the Commission for considering our comments
regarding the proposed rule changes in the above docket. After several opportunities to provide
comments at the workshops in this matter, we have additional comments regarding the proposed
rule changes.
Rocky Mountain Power is neutral to the maj ority of the proposed rule changes due to
consistency with our normal business practices. We limit our comments today to three areas:
Rules 203, 204, and 311 as follows:
203. BILLING UNDER INAPPROPRIATE TARIFF SCHEDULE
204. INACCURATELY BILLED SERVICE UNDER CORRECT TARIFF SCHEDULE
FAILURE TO BILL FOR SERVICE.
Rocky Mountain Power objects to the proposed changes to the rebilling time periods in Rule 203
Section 03. and Rule 204 Section 02. The company s objection pertains to the change in
symmetry between rebilling for overcharges and undercharges. The company also objects to the
requirements in both rules and sections that the company implement procedures designed to
monitor and identify customers who may be billed under an inappropriate tariff schedule.
Change in Symmetry for Rebilling
The proposed change is inequitable in that it limits the timeffame for undercharging customers to
six months while permitting adjustments for overcharges to remain at three years. The company
submits that there is no reasonable basis for changing a rule that presently provides symmetry
between time periods for rebilling due to overcharges and undercharges to a rule that eliminates
symmetry and results in such disparate treatment. If the Commission is concerned with the
length of time associated with rebilling, then the limitation to six months should be implemented
for both overcharging and undercharging providing symmetry between the two scenarios. As
long as there is symmetry, Rocky Mountain Power would be supportive of a reasonable change
in time period associated with rebilling for overcharges and undercharges.
Implementation of New Procedures
The requirement that utilities implement new procedures to monitor and identify customers who
may be billed under an inappropriate rate schedule is problematic for Rocky Mountain Power
because of cost, time, and special metering such as demand meters or time-of-use meters
required to compare applicability of rate schedules. In addition, Rocky Mountain Power s Large
Account Managers review their client's usage and rate schedules and utilize dedicated phone
lines for small business and irrigation customers to them. Rocky Mountain Power also provides
optional rate schedules for customers at the time an application for service is made. The option
rate schedules are sent via U. S. mail at the time the customer signs up for service and again
annually with a Consumer Information Guide, which is a PURP A mandated mailing. If the
company s present practices of sending information through its mailings and the use of
specialized personnel meet the requirements of this proposed rule change, then the company has
no objection with the proposed change. However, if the company would be required to initiate
new procedures and incur additional costs, the company objects to this proposed change.
311. TIMES WHEN SERVICE MAY BE DENIED OR TERMINATED - OPPORTUNITY
TO A VOID TERMINATION OF SERVICE.
Rocky Mountain Power does not support the proposed changes to rule 311. As a matter of
practice, Rocky Mountain Power does not typically disconnect service of residential customers
for non-payment on Fridays. However, there are times when the disconnection work cannot be
completed Monday through Thursday, and the company must utilize the current provision
flexibility to permit disconnects until 12 noon on Fridays. As such, the company would prefer
the rule continue to allow disconnects until 12 noon on Fridays, or, at a minimum, limit the
application of the proposed rule change to the residential class.
Rocky Mountain Power also objects to the proposed rule change that prohibits a utility from
denying service on a Friday. The proposed rule is vague because it implies that a utility may be
in violation of the rule even if an applicant is simply notified on a Friday that the utility is
denying service.
Thank you for the opportunity to participate in the rulemaking process and for consideration of
our comments. Communications regarding the company s comments in this matter may be
addressed to:
Robin Cross
Customer & Regulatory Liaison
Rocky Mountain Power
825 N.E. Multnomah, Suite 800
Portland, OR 97232
Telephone [phone]
Email: robin. cross(illpacificorp. com
Justin Lee Brown
Senior Counsel
Rocky Mountain Power
201 South Main Street, Suite 2300
Salt Lake City, UT 84111
Telephone: [phone]
Email: justin.brown(illpacificorp.com
Sincerely,~~/fP
Robin Cross
Customer & Regulatory Liaison