Case Background
On November 7,
2019, Peoples Gas System (Peoples or utility) filed a petition for approval of
tariff modifications to the Natural Choice Transportation Service (NCTS) Rider,
the Gas Service Agreement (GSA), and the NCTS Letter of Authorization. Peoples’
NCTS Rider program was approved in July 2000. The program allows qualifying
customers to purchase natural gas directly from a pool manager, while paying
Peoples for the transportation of natural gas on its system. The NCTS Letter of Authorization is the
formal request by the customer for gas transportation service pursuant to
Peoples’ NCTS Rider. The GSA is a standard form, completed by the customer, to
initiate natural gas service with Peoples. The GSA is found on Tariff Sheet No.
8.102.
The proposed
tariff sheets are shown in Attachment A to the recommendation. The utility
waived the 60-day file and suspend provision of Section 366.06(3), Florida
Statutes (F.S.), until the February 4, 2020 Agenda Conference. On January 22,
2020, Peoples filed a minor correction to Tariff Sheet No. 8.102. The
Commission has jurisdiction over this matter pursuant to Sections 366.03,
366.04, 366.05, and 366.06, F.S.
Discussion
of Issues
Issue 1:
Should the Commission approve Peoples' proposed
tariff sheet modifications as shown in Attachment A?
Recommendation:
Yes. The Commission should approve Peoples’ proposed
modifications as shown in Attachment A to the recommendation. The revised
tariffs should become effective with the Commission’s vote on February 4, 2020.
(Ward)
Staff Analysis:
Rule 25-7.0335, Florida Administrative Code
(F.A.C.), requires local distribution companies (LDCs) to make gas
transportation service available to non-residential customers. The rule also
allows LDCs to offer transportation service to residential customers.
Transportation service is a voluntary program that allows customers to purchase
natural gas from a third-party marketer, or pool manager.
Peoples functions as a traditional LDC, providing gas
service for sales customers, while also providing optional transportation
service as required by Rule 25-7.0335, F.A.C. There are currently 27,000
customers participating in Peoples’ NCTS program, along with 15 approved pool
managers. The transportation customers pay the pool manager’s charges for
natural gas and are not subject to the utility’s Commission-approved Purchased
Gas Adjustment (PGA) rates, whereas sales customers are subject to PGA rates.
The Commission does not approve or review natural gas prices pool managers
charge their customers.
The NCTS Rider (Tariff Sheets Nos. 7.803-7.803.3) and
associated tariffs provide the terms and conditions under which Peoples allows participating
commercial and large residential customers to use a pool manager to purchase
their natural gas. In the instant docket, the utility seeks to modify Tariff
Sheet Nos. 7.803-2 and 7.803-3 to change the date by which the pool managers
enroll a customer in the NCTS program. Peoples seeks to change the enrollment
date from the twentieth day of the month to the fifteenth day of the month.
Peoples states that this change would provide pool managers additional time to
complete their therm usage forecast for the upcoming month, resulting in more
timely and accurate gas supply nominations by the pool manager. The utility
also seeks to modify Tariff Sheet No. 7.803-3 to change the deadline by which
the pool manager may submit a request to terminate a customer to the sixteenth
day of the month prior to termination. The current deadline is 30 days prior to
the first day of the month that the termination is to take place. Peoples
states that this requested modification would provide pool managers with more
flexibility, by reducing the time frame for notification to Peoples when shifting
customers between marketers, or returning customers to system supply.
Second, Peoples seeks to modify its NCTS Letter of
Authorization, contained in Tariff Sheet Nos. 8.118-8.118.2. The utility is
proposing to streamline the process by modernizing the terminology, allowing
for electronic signatures, and making the form more compatible with its
internal information systems. Peoples states that the modified form would
simplify the enrollment process and de-enrollment process in the NCTS program.
Peoples also modified Tariff Sheet No. 8.118-2 to allow a pool manager to
complete one Letter of Authorization for a customer with multiple meters at one
location.
Finally, Peoples seeks to modify its Gas Service
Agreement, contained within Tariff Sheet No. 8.102, which was last modified in 2003.
The utility states that modification is required to simplify the terminology,
allow for electronic signatures, and generally make the form and the
information it provides more compatible with their internal information system
supporting the NCTS program. The
utility states that in October 2019, it provided pool managers with an overview
of the Gas Management System and an update on the proposed changes contained in
the instant petition. Peoples asserts that none of the pool managers have
expressed any concerns with the proposed modifications.
Conclusion
Staff notes that the requested tariff revisions are
intended to provide the pool managers with additional time each month to
complete their therm usage forecasts, while also allowing more flexibility in
their time frame to submit a request to terminate a customer. The modifications
would also modernize the terminology and allow for electronic signatures on the
NCTS Letter of Authorization and the GSA. Staff believes that the proposed
modifications are reasonable and would meet their intended purpose.
In light of the foregoing, the Commission should approve
Peoples’ proposed modifications as shown in Attachment A to the recommendation.
The revised tariffs should become
effective with the Commission’s vote on February 4, 2020.
Issue 2:
Should this docket be closed?
Recommendation:
If Issue 1 is approved and 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 issuance of a
consummating order. (Brownless)
Staff Analysis:
If Issue 1 is approved and 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.
