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.