20101129_3164.pdf

DECISION MEMORANDUM
TO:COMMISSIONER KEMPTON
COMMISSIONER SMITH
COMMISSIONER REDFORD
COMMISSION SECRETARY
LEGAL
WORKING FILE
FROM:MATT ELAM
DATE:NOVEMBER 24 2010
SUBJECT:A VISTA'S TARIFF ADVICE - SCHEDULE 146 REVISIONS
On October 15 2010, Avista filed a Tariff Advice proposing changes to the terms and
conditions of Transportation Schedule 146. The Company requested an effective date of
December 1 2010. On November 3 2010, the Company filed substitute tariff sheets removing a
provision from the terms and conditions allowing transportation customers to contract with the
Company for a specified daily quantity of sales gas. The proposed changes are intended to
address the customer s agent and its role in delivering gas, and to pass along penalties that
protect system customers from the costs of mismanaged supplies.
THE TARIFF ADVICE
Currently, Avista s Schedule 146 terms and conditions do not address the customer
agent and its role in delivering gas. According to the Company, it has become common for
transportation customers to contract with an agent, who acquires the gas and pipeline
transportation for delivery to the Company s system. The agent will "pool" the nominations of
the Company s transportation customers and then provide a daily nomination to the Company for
that amount of customer-owned gas delivered to the system. The Company incorporates these
daily nominations into its daily nominations provided to the pipeline transporter.
The proposed changes make the agent responsible for nominating and balancing gas
supplies for all customers in its pool. The agent would be billed for the entitlement and supply
imbalance penalties on behalf of customers in its pool. Unlike the present schedule which states
that the customer is responsible for all applicable penalties, the customer would only be billed for
entitlement and balancing penalties ifthey are not part of an agent's supply pool. Referencing
the provision numbers on the proposed tariff, the Company proposes to add: (1) Provision No.
describing the role and requirements ofthe customer s agent, (2) Provision No.9 requiring
DECISION MEMORANDUM NOVEMBER 24 2010
customers to show credit worthiness ifthe nominated volumes are not delivered, and (3)
Provision No. 11 assigning a penalty for unreasonable imbalance levels. The Company proposes
to change: (1) Provision No.2 clarifying the customer s payment responsibilities to suppliers, (2)
Provision No.3 clarifying the customer s payment responsibilities on customer owned gas
transported by the Company, (3) Provision No.4 removing standard protocol language regarding
metering equipment owned and maintained by the Company, (4) Provision No.7 assigning a
penalty for unauthorized over usage during "overrun entitlement periods " and (5) Provision No.
8 assigning a penalty for unauthorized under usage during '\1nderrun entitlement periods.
STAFF REVIEW
Staff reviewed the Company s proposed additions and changes to the terms and
conditions of Schedule .146, specifically:
1) Transportation tariffs in the Company s otherjurisdictions
2) Transportation tariffs of other local distribution companies, and
3) The Company s process for notifying customers.
Staff found several differences in the Company s proposal to its transportation tariffs in
its other jurisdictions. However, according to the Company, the proposed changes will make its
tariff the same as its recent tariff proposal filed in Washington. After reviewing the
transportation tariffs of other local distribution companies, Staff believes the Company
proposal is reasonable. The Company sent an adequate notice to customers regarding the
changes.
STAFF RECOMMENDATION
Staff recommends that Avista Utilities' Tariff Advice to change Schedule 146 be
approved and the associated tariff sheet revisions be allowed to go into effect on December 1
2010. Staff believes that the proposed changes satisfy the Commission s Rule of Procedure for
Tariff Advices, Rule 134, IDAPA 31.01.01.134.
COMMISSION DECISION
Does the Commission wish to approve the Tariff changes to Schedule 146?
i:udmemos/ A vista schedule 146 T A.doc
Matt Elam
DECISION MEMORANDUM NOVEMBER 24 2010