Discussion
of Issues
Issue 1:
Should the Commission approve DEF's proposed modifications
to its LS-1 rate schedule as shown in Attachment 1?
Recommendation:
Yes. The Commission should approve DEF’s proposed modifications
to its LS-1 rate schedule as shown in Attachment 1. The proposed new LED
fixture and pole options are cost based and expand the fixture and pole options
available to customers. Closing the current metal halide and sodium vapor
options for new installations allows DEF to recognize energy efficiencies and
technological improvements in the lighting industry. The revised tariffs should
become effective on March 5, 2019. (Guffey)
Staff Analysis:
DEF’s LS-1 rate schedule is available to customers
for the purpose of lighting roadways and other outdoor areas. DEF proposed four
revisions to its LS-1 rate schedule which are discussed below.
First, DEF proposed to close the metal halide fixture
options for new installations. Existing metal halide lighting customers can
continue to use them until either the fixture or the ballast, or both, fails. The ballast
regulates the current to the lamps and provides voltage to start the lamps. At
the time of fixture or ballast failure, the metal halide fixture will be
replaced with a comparable LED fixture and applicable monthly rates will apply.
LED fixtures do
not require a ballast to
regulate the current.
DEF explained that the Energy Independence and Security
Act of 2007 requires that ballasts installed in metal halide fixtures meet
higher energy efficiency standards, and as of early 2017, certain metal halide
lamps of certain wattages cannot contain a probe-start ballast. DEF stated that
metal halide fixtures and ballasts have been gradually phased out in order to
meet the Energy Independence and Security Act of 2007 guideline requirements;
therefore, manufacturers no longer produce metal halide fixtures.
Second, DEF proposed to close the sodium vapor fixture
options for new installations. Although the Energy Independence and Security
Act of 2007 does not limit the production of ballasts for sodium vapor fixtures,
manufacturers are now primarily producing LED fixtures. DEF contends that the
market is moving towards higher energy efficiency lighting technology and
customers also prefer LED lighting.
Existing sodium vapor lighting customers can continue to
use them until the fixture fails or the damaged fixture needs repair along with
the replacement of the ballast. At that time, DEF explained that it will work
with the customer to find a sodium vapor fixture that matches what is currently
in the neighborhood or replace the sodium vapor fixture with a comparable LED
fixture. DEF stated that as manufacturers continue to transition away from
sodium vapor lights towards LED fixtures, finding a matching sodium vapor
fixture may become increasingly difficult.
Third, in order to expand the fixture and pole options
available to customers, DEF proposed to add several new LED fixtures and pole options
to its existing offerings. The proposed new fixtures and poles are shown in
revised Tariff Sheet Nos. 6.2811, 6.2812, 6.282 and 6.2821.
The utility provided cost support information for the
newly introduced LED fixtures and poles. The charges for the LED fixtures are
comprised of three components: a fixture charge, a maintenance charge, and a
non-fuel energy charge, consistent with DEF’s other lighting options.
The fixture charges were developed based on material, design, labor,
storage, and vehicle costs associated with the installation multiplied by the
currently approved 1.59 percent fixture rental rate to determine the monthly
fixture charge. The maintenance charges were developed based on DEF’s estimated
maintenance cost for the components (e.g., driver, photo control, luminaire) of
the fixtures. The non-fuel energy charge is determined by multiplying the
estimated kilowatt-hour usage by fixture type by the currently approved
non-fuel energy charge for lighting service (2.547 cents per kilowatt-hour).
All other Commission-approved LS-1 recovery clause factors will be applied to
the estimated usage.
The monthly pole charges were developed based on the
material costs and DEF’s labor rates to install a pole multiplied by the
currently approved 1.82 percent pole rental rate. The new pole types are
aluminum or concrete.
Finally, DEF proposed to update Note 2 under Notes to Per
Unit Charges on revised tariff sheet No. 6.283. The proposed revision will make
the note more applicable to LED lighting fixtures, which do not contain
ballasts, and state that the wattage ratings may vary with lamp configuration.
Conclusion
Staff reviewed the petition, data responses, and the necessary
cost support information submitted by DEF, and believes the charges are
reasonable and appropriate. The proposed new LED fixture and pole options are
cost based and expand the fixture and pole options available to customers.
Closing the current metal halide and sodium vapor options to new customers
allows DEF to recognize energy efficiencies and technological improvements in
the lighting industry. Staff recommends that DEF’s proposed modifications to
its LS-1 rate schedule as shown in Attachment 1 be approved. The revised
tariffs should become effective on March 5, 2019.
Issue 2:
Should this docket be closed?
Recommendation:
If a protest is filed within 21 days of the issuance
of the order, the tariffs should remain in effect, with any revenues held
subject to refund, pending resolution of the protest. If no timely protest is
filed, this docket should be closed upon the issuance of a consummating order.
(Simmons)
Staff Analysis:
If a protest is filed within 21 days of the issuance
of the order, the tariffs should remain in effect, with any revenues held
subject to refund, pending resolution of the protests. If no timely protest is
filed, this docket should be closed upon the issuance of a consummating order.
