20180928Decision Memo.pdf

DECISION MEMORANDUM
TO:COMMISSIONER KJELLANDER
COMMISSIONER RAPER
COMMISSIONER ANDERSON
COMMISSION SECRETARY
COMMISSION STAFF
LEGAL
FROM:BRANDON KARPEN
DEPUTY ATTORNEY GENERAL
DATE: SEPTEMBER 21,2018
SUBJECT: AVISTA,S APPLICATION TO REVISE TARIFF SCHEDULE 170
NATURAL GAS RULES AND REGULATIONS; CASE NO. AWI-G-18-07.
On September 19,2018, Avista Corporation dba Avista Utilities filed an Application
requesting that the Commission approve changes to the Company's Tariff Schedule 170 relating
to the Company's Natural Gas Rules and Regulations. The proposed changes stem from the
Company's effort to comply with Commission Order No. 33953.
Generally, the Company proposes to incorporate pertinent provisions of the
Commission's Service Rules for Gas Utilities (IDAPA 31.31.01), including rules for meter
testing and accuracy as well as maintaining system maps and records. The Company proposes to
move these relevant requirements into the Company's tariff.
BACKGROUND
In July 2008, Staff received an inquiry from Avista regarding an apparent conflict
between Commission Gas Service Rule 102, and Commission Safety Rule 202, relating to the
Commission's adoption of the National Fuel Gas Code, the Uniform Mechanical Code, and the
International Mechanical Code. After reviewing the issue, the Commission concluded that Gas
Service Rule 102 is incompatible with the Commission's Safety Rules 202.02 and203.02. Order
30625 at 2. Consequently, the Commission suspended Gas Service Rule 102, IDAPA
31.31.01 .102. Id. at 3. The Commission further directed Staff to work with gas utilities and other
interested persons and informally review the Gas Service Rules. 1d.
IDECISION MEMORANDUM
Avista and other natural gas utilities provided Staff with proposed changes to IDAPA
31.31.01 in November 2016, consistent with current best practices. Further discussions led to an
agreement that the integration of these revisions into the Company's tariffs would be beneficial
to the Company and the Commission. As such, in the Company's 2017 General Rate Case, the
matter of incorporating pertinent provisions from IDAPA 31.31.01 was made part of the ultimate
settlement resolving the case.
On December 28, 2017, the Commission issued Order No. 33953, approving the
Settlement Stipulation in the rate case. Therein, the parties agreed:
The Company and interested parties will meet and confer to review the
Commission's Service Rules for Gas Utilities (IDAPA 31.31.01) to determine
which provisions should be retained and/or modified, and, if the participants
agree, incorporate those changes into the Company's tariff. Any changes
requiring Commission approval, e.g., tariff revisions, will be submitted by the
Company on or before [October l, 201 8]. '
Stipulation and Settlement Para. 19. If the underlying Application is approved, the rules
developed with Staff will be incorporated into Avista Natural Gas Tariff Schedule 170. Approval
of the rules would not change rates. The Company requested that the Commission process this
Application under Modified Procedure, with an effective date of November 1,2018. Application
at 8.
PROPOSED TARIFF CHANGES
By way of summary, the Company seeks to add three new sections to Tariff Schedule
170, as follows:
l. Meter Accuracy: This change will add rules requiring the Company to afford
customers with meters that provide adequate pressure, heat content, and accurate measurement of
gas consumption.
2. Meter Testing: This change will add rules requiring the Company to maintain
meter records, the parameters for new and installed meter testing programs, including
methodology.
I On June 25, 2018, Avista requested, and the Commission approved, an extension to a July l,
2018, deadline to submit proposed rules to allow sufficient time to complete the work on the proposal.
Order No. 34102.
2DECISION MEMORANDUM
3. Maps and Records of Facilities: This change will add rules requiring the
Company to keep maps and records that show the size, character, and Iocation of each street
main, district regulator, street valve, and service connection in the corresponding territory served.
STAFF RE,COMMENDATION
Staff concurs that Modified Procedure is an appropriate means to process Avista's
Application. Staff recommends that the Commission issue a Notice of Application and establish
a general comment deadline of October 17, 2018, and an October 22, 2018 deadline for the
Company to file a reply.
COMMISSION DECISION
Does the Commission find that Modified Procedure is an appropriate means to
process this case with a general comment deadline of October 17 ,2018, and an October 22,2018
deadline for the Company to file a reply?
// /LF-,B*il4;;t".p*
Deputy Attorney General
I \Legal\GAS\AVU-G- I 8-07\MEMOS\AWG I 807_bk.doc
JDECISION MEMORANDUM