WREA Comments Section 25-37 - Wyoming Public Service
Transcription
WREA Comments Section 25-37 - Wyoming Public Service
2312 Carey Avenue Cheyenne, Wyoming 82001 (307) 634-0727 Fax: (307) 634-0728 _________________________________________________________________________________________ MEMO TO: PUBLIC SERVICE COMMISSION – CHRIS PETRIE FROM: SHAWN TAYLOR SUBJECT: QUESTIONS FOR TECHNICAL CONFERENCE DATE: 5/15/2015 Below are questions, suggestions and points of clarification for the second round of consideration of rule changes from section 25-37 Section 25. Conformance with Revised Commission Rules and Regulations If a change to the Commission’s Rules and Regulations renders a utility’s tariff nonconforming, the utility shall file a conforming tariff within 90 days of the effective date of the change to the Commission’s Rules and Regulations. Request more than 90 days due to the extensive nature of this re-write. Section 26. Pass-On Applications and Commodity Balancing Accounts (CBA) (249-250) Would like language that specifically states that this section does not apply to utilities that are not rate regulated. Section 27. SIRT; Reportable Incidents (231-235) 27 (c)(i) Sustained outages to 500 or 50% of residential customers, whichever is fewer. What is the definition of “sustained outage”? Section 28. Interruption of Service Reporting (238, 325, 420) 28(a)(i) Each utility shall report within 30 days after the end of each calendar quarter the following service interruptions, planned or otherwise: Electric utilities: all service interruptions lasting 5 minutes or longer. Request extension of 5 minute time of outage. 28(b) By May 1 of each year, each electric utility shall file its Reporting Plan, including proposed modifications and definitions of major and minor service interruptions specific to the utility’s system. If, after the utility’s review, there is no change to the Plan, the utility shall so notify the Commission by letter. What are you looking for in the Reporting Plan? We believe the Plan is defined by the commission and we simply follow your requirements. Section 34. Continuity of Operation Plans. The Commission may require a utility to file a Continuity of Operations Plan. What is the Commissions’ goal in possibly requiring a Continuity of Operations Plan? Section 37. Cooperative Utilities. (223(b), 318-324) Would like language clarifying that this section pertains to rate regulated cooperatives only.